• Comments

Joint Response to ABS Conflicts of Interests Proposal

Comments submitted by a NABL-led coalition in response to the SEC’s request for comments on its proposed rule “Prohibition Against Conflicts of Interest in Certain Securitizations.”


Statute passed in the wake of the 2008-2009 financial meltdown that enacted sweeping changes in the regulation of financial institutions, municipal advisors, and the financial markets.

  • Comments

Response to MSRB Proposal to Improve Disclosure of Direct Purchases and Bank Loans (Notice 2016-11)

Comments relating to MSRB Regulatory Notice 2016-11 (March 28, 2016), in which the Municipal Securities Rulemaking Board solicited comments on a concept proposal to require municipal advisors to disclose information…

  • Comments

Response to MSRB Notice 2014-01 (On Rule G-42)

Response to the Municipal Securities Rulemaking Board’s(MSRB’s) solicitation of comments on MSRB Notice 2014-01 related to its draft of Rule G-42 – “Duties of Non-Solicitor Municipal Advisors”

  • Comments

Response to SEC Proposal on Proprietary Trading (Release No. 34-65545)

Response to the Securities and Exchange Commission (“SEC”) solicitation of comments related to SEC Release No. 34-65545 (File No. S7-41-11) on Prohibitions and Restrictions on Proprietary Trading and Certain Interests…

  • Comments

Response to SEC Release 34-64766 (On Business Standards for Swap Participants)

Comments submitted to the Securities and Exchange Commission (SEC) relating to Release No. 34-64766, Business Conduct Standards for Security-Based Swap Dealers and Major Security Based Swap Participants, dated June 29,…

  • Comments

Response to Proposed Credit Risk Retention Rule (Release No. 34-64148)

Comments to the proposed rule published April 29, 2011, at 76 FR 24090 (the “Proposing Release”) on Credit Risk Retention by the Agencies to implement the credit risk retention requirements…

  • Comments

On SEC Release Number 34-63576 (Registration of MAs)

Comments submitted in response to the U.S. Securities and Exchange Commission (SEC) Release Number 43-63576 relating. which solicited comments on Rules 15Ba1-1 through 15Ba1-7 (collectively, the “Proposed Rules”) proposed to…

  • Comments

Response to SEC Proposals Regarding Asset-Backed Securities (ABSs)

Response to the Securities and Exchange Commission (“SEC”) solicitation of comments related to several releases (33-9148, 34-63029, 33-9150, and 34-63091) regarding regulation of asset-backed securities post-Dodd-Frank.

  • Reports and Resources

Summary of Dodd-Frank Provisions Relating to Municipal Securities

A summary of provisions relating to municipal securities included in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Pub. L. No. 111-205).

  • Comments

PFN Letter Urging Amendment to Restoring American Financial Stability Act

Letter from the Public Finance Network (PFN) urging Congress to amend Section 941 of the Restoring American Financial Stability Act of 2010 (Act) to explicitly exclude municipal securities from its…