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.”
Suppl. Comments on IRS Notices 2022-49 and 2022-50
Follow up comments to a November 4, 2022 letter sent by NABL suggesting various areas of need for guidance relating to certain tax provisions enacted under the Inflation Reduction Act…
Request for Guidance On Qualified Broadband Bonds
Comments submitted to the Internal Revenue Service (IRS) requesting clarifying guidance pertaining to the recently enacted qualified broadband project bonds.
Declaration of Intent Requirement of Treasury Regulations § 1.150-2
Commentary sent to Treasury and the IRS describing the declaration of intent requirement for bond proceeds used to reimburse prior expenditures contained in Treasury Regulations § 1.150-2 and setting forth…
Issuer Letter on PAYGO Sequestration
On December 15, 2022, issuer representative groups of the Public Finance Network (PFN) sent a letter urging Congress to address pending Pay As You Go (“PAYGO”) scorecards before the end…
Comments on Proposed SLGS Rule Changes
Response to proposed regulations from the Bureau of Fiscal Services (BFS) pertaining to the State and Local Government Series (“SLGS”) securities program.
Response to IRS Requests on IRA Implementation
Comments submitted in response to a solicitation from the Internal Revenue Service (Notices 2022-49 and 2022-50) for requests for guidance relating to certain tax law changes enacted by the Inflation…
Comments to Final LIBOR Rule
Comments submitted in response to the final promulgation of Final Treasury Regulations §1.1001-6 and Final Amendments to §1.1275-2 relating to the transition from interbank offered rates (IBORs) to replacement benchmark…
DIG Letter on Section 203 of the Financial Data Transparency Act (FDTA)
Coalition letter from the Disclosure Industry Group (DIG), including NABL, that outlines various concerns pertaining to Section 203 of the Financial Data Transparency Act (FDTA).
PFN Letter on the Financial Data Transparency Act (FDTA)
Letter from various members of the Public Finance Network (PFN) expressing serious concerns pertaining to the Financial Data Transparency Act (FDTA) gaining support in the 117th Senate.
Congratulations to Commissioners Lizárraga and Uyeda
Letter congratulating Commissioners Jaime Lizárraga and Mark Uyeda on their recent Senate confirmations to serve on the U.S. Securities and Exchange Commission (SEC).
Request for IRS Guidance on Carbon Capture Bonds
Request for the Internal Revenue Service (IRS) to issue clarifying guidance surrounding qualified carbon dioxide capture facilities enacted under the Infrastructure Investment and Jobs Act (IIJA) of 2021.