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Comments on FINRA Rulemaking

Notice of Filing of a Proposed Rule Change to Amend FINRA Rule 4210 (Margin Requirements) to Establish Margin Requirements for the TBA Market

(Release No. 34-76148; File No. SR-FINRA-2015-036)


Submitted Comments

(Click here for meetings with SEC officials)
Comments have been received from individuals and entities using the following Letter Type A: 50
Comments have been received from individuals and entities using the following Letter Type B: 4
Sep. 10, 2021 Thomas J. Fleming and Adrienne M. Ward on behalf of Bond Dealers Association and Brean Capital, Olshan Frome Wolosky
Mar. 7, 2018 Chris Killian, Managing Director, SIFMA
Jan. 9, 2018 Thomas J. Fleming, Olshan Frome Wolosky LLP, on behalf of Brean Capital LLC
Nov. 10, 2017 Thomas J. Fleming, Olshan Frome Wolosky LLP, on behalf of Brean Capital LLC
Jun. 14, 2016 Robert W. Errett, Deputy Secretary, Securities and Exchange Commission
May 26, 2016 Mike Nicholas, Chief Executive Officer, Bond Dealers of America
May 2, 2016 David H. Stevens, President and Chief Executive Officer, Mortgage Bankers Association
May 2, 2016 Christopher B. Killian, Managing Director, Securitization, SIFMA
May 2, 2016 James M. Cain, Sutherland Asbill & Brennan LLP on behalf of the Banks of the Farm Credit System
May 2, 2016 James M. Cain, Sutherland Asbill & Brennan LLP on behalf of the Federal Home Loan Banks
May 2, 2016 Chris Melton, Executive Vice President, Coastal Securities, Houston, Texas
May 2, 2016 Michael Nicholas, CEO, Bond Dealers of America, Washington, District of Columbia
May 2, 2016 Manisha Kimmel, Chief Regulatory Officer, Wealth Management, Thomson Reuters
Apr. 27, 2016 Robert Fine, Chief Executive Officer, Brean Capital, LLC
Mar. 1, 2016 Lauren Eardensohn Sarper, Director, Policy Development, External Affairs, Prudential Financial, Inc.
Feb. 17, 2016 Robert Tirschwell
Feb. 11, 2016 Sen. Tom Cotton, United States Senate
Feb. 11, 2016 David H. Stevens, CMB, President and CEO, Mortgage Bankers Association
Feb. 11, 2016 Carl B. Wilkerson, Vice President & Chief Counsel, Securities & Litigation, American Council of Life Insurers
Feb. 11, 2016 James M. Cain, Sutherland Asbill & Brennan LLP, on behalf of Federal Home Loan Banks
Feb. 11, 2016 Michael McRoberts, Managing Director, Prudential Mortgage Capital Company
Feb. 11, 2016 Timothy W. Cameron, Esq. Managing Director, and Laura Martin Managing Director & Associate General Counsel, Asset Management Group, Securities Industry and Financial Markets Association
Feb. 11, 2016 Bruce Sandweiss, Executive Vice President, Gershman Mortgage
Feb. 11, 2016 Roderick D. Owens, Executive Director, Committee on Healthcare Financing
Feb. 11, 2016 Timothy W. Cameron, Esq. Managing Director, and Matthew J. Nevins, Esq. Managing Director and Associate General Counsel, Asset Management Group, Securities Industry and Financial Markets Association
Feb. 11, 2016 John R. Gidman, President, Association of Institutional INVESTORS
Feb. 11, 2016 Allen Riggs, Chief Financial Officer, Vining Sparks IBG, LP
Feb. 11, 2016 Blake Lanford, Managing Director, Walker & Dunlop, LLC
Feb. 11, 2016 Mike Nicholas, CEO, Bond Dealers of America, Washington, District of Columbia
Feb. 11, 2016 Robert T. Kirkwood, Chief Operating Officer, Lancaster Pollard Holdings, LLC
Feb. 11, 2016 Tony Love, Vice President, Forest City Capital Corporation
Feb. 11, 2016 Steve Wendel, Managing Director, CBRE Inc., Boston, Massachusetts
Feb. 10, 2016 Rodrigo López, CMB, Executive Chairman, NorthMarq Capital Finance
Feb. 10, 2016 Chris Melton, Executive Vice President, Costal Securities
Feb. 9, 2015 Holly MacDonald-Korth, Managing Director, J W Korth & Company
Feb. 9, 2015 Tari Flannery, President, M&T Realty Capital Corporation
Feb. 9, 2015 Matrix Applications
Jan. 11, 2015 David H. Stevens, President and Chief Executive Officer, Mortgage Bankers Association
Jan. 4, 2015 Carl E. Corrado, Executive Vice President, Great Lakes Financial Group, LP
Nov. 23, 2015 Mark C. Unangst, Senior Vice President, Gershman Mortgage
Nov. 18, 2015 Bruce Sandweiss, Executive Vice President, Gershman Mortgage
Nov. 10, 2015 Carl B. Wilkerson, Vice President & Chief Counsel, Securities & Litigation, American Council of Life Insurers
Nov. 10, 2015 David H. Stevens, President and Chief Executive Officer, Mortgage Bankers Association
Nov. 10, 2015 Mary Kay Scucci, Managing Director, and Christopher B. Killian, Managing Director, SIFMA
Nov. 10, 2015 Robert B. Engel, Chief Executive Officer, CoBank, ACB, Greenwood Village, Colorado
Nov. 10, 2015 Robert Tirschwell, Head of Fixed Income Trading, Brean Capital, LLC
Nov. 10, 2015 American Seniors Housing Association, et al.
Nov. 10, 2015 Timothy W. Cameron, Esq. Managing Director, and Matthew J. Nevins, Esq., Managing Director and Associate General Counsel, Asset Management Group, Securities Industry and Financial Markets Association
Nov. 10, 2015 James M. Cain, Sutherland Asbill & Brennan LLP, on behalf of Federal Home Loan Banks
Nov. 10, 2015 Dennis G. Morton, President, AJM First Capital, LLC
Nov. 10, 2015 Paul J. Barrese, Sandler O'Neill Partners, L.P., New York, New York
Nov. 10, 2015 John R. Gidman, President, Association of Institutional INVESTORS
Nov. 10, 2015 Stephen P. Theobald, Executive Vice President and Chief Financial Officer, Walker & Dunlop, LLC
Nov. 10, 2015 Robert Cahn, Senior Vice President, Prudential Mortgage Capital Company
Nov. 10, 2015 Robert T. Kirkwood, Chief Operating Officer, Lancaster Pollard Holdings, LLC
Nov. 10, 2015 Michael Nicholas, CEO, Bond Dealers of America, Washington, District of Columbia
Nov. 10, 2015 Charles M. Weber, Robert W. Baird Co. Incorporated, Managing Director and Senior Associate General Counsel, Milwaukee, Wisconsin
Nov. 10, 2015 Robert H. Huntington, Managing Director, Credit Suisse Securities (USA) LLC
Nov. 10, 2015 Matrix Applications, LLC
Nov. 10, 2015 Bernard P. Gawley, Chief HUD Underwriter, The Ziegler Financing Corporation
Nov. 10, 2015 Diane N. Marshall, President, Prairie Mortgage Company
Nov. 10, 2015 James F. Croft, Senior Managing Director, Red Mortgage Capital
Nov. 10, 2015 Jayson F. Donaldson, President, NorthMarq Capital Finance, L.L.C.
Nov. 10, 2015 Robert M. Fine, Chief Executive Officer, Brean Capital, LLC, New York, New York
Nov. 10, 2015 Douglas I. McCree, CMB, President and CEO, First Housing, Tampa, Florida
Nov. 10, 2015 Deborah Rogan, Executive Vice President, Bellwether Enterprise Real Estate Capital, LLC
Nov. 10, 2015 Lee Oller, Senior Vice President, Draper and Kramer Commercial Mortgage Corp.
Nov. 10, 2015 Tony Love, Vice President, Forest City Capital Corporation
Nov. 10, 2015 Doug Bibby, President, National Multifamily Housing Council, and Doug Culkin, President and CEO, National Apartment Association
Nov. 10, 2015 Tyler Griffin, COO, Dwight Capital
Nov. 10, 2015 Steve Wendel, Managing Director, CBRE, Inc.
Nov. 10, 2015 Margaret Allen, Chief Executive, AGM Financial
Nov. 9, 2015 Anthony Luzzi, President, Sims Mortgage Funding, Inc.
Nov. 9, 2015 Matthew Kane, President, Centennial Mortgage, Inc.
Nov. 9, 2015 David F. Perry, President, Century Health Capital, Inc.
Nov. 9, 2015 Jonathan S. Camps, Senior Vice President, Love Funding
Nov. 9, 2015 Richard A Carlson, Chief Financial Officer, Davis-Penn Mortgage Co.
Nov. 9, 2015 Dan Darilek, Senior Vice President, Davis-Penn Mortgage Co.
Nov. 9, 2015 Craig Singer, Managing Director, and James Hussey, CFO, Head of Servicing, RICHMAC Funding LLC
Nov. 9, 2015 David W. Blass, General Counsel, Investment Company Institute
Nov. 9, 2015 Michael S. Cordes, Managing Director, ColumbiaNational Real Estate Finance, LLC
Nov. 9, 2015 Jose A. (Tony) Perez
Nov. 9, 2015 Tari Flannery, President, M & T Realty Capital Corporation
Nov. 9, 2015 Chris Melton, Houston, Texas
Nov. 6, 2015 John O. Moore Jr. (Chip), President , Highland Commercial Mortgage
Nov. 6, 2015 Daniel R. Crain, President, Crain Mortgage Group, LLC
Nov. 6, 2015 Roderick D. Owens, Esq., Executive Director, Committee on Healthcare Financing
Nov. 6, 2015 Keith J. Gloeckl, Chief Executive Officer, Churchill Stateside Group
Nov. 5, 2015 Tony Love, Vice President, Forest City Capital Corporation
Nov. 5, 2015 Pete Hodo, III, Chief Operating Officer & Principal, Highland Commercial Mortgage, LLC
Nov. 2, 2015 Michael McRoberts, Chairman, DUS Peer Group
Oct. 29, 2015 Mortgage Bankers Association, et al.
 

Meetings with SEC Officials

(
Click here for submitted comments from the public)
Jun. 14, 2016 Memorandum from the Division of Trading and Markets regarding a June 14, 2016, telephonic meeting with representatives of Brean Capital, LLC
May 16, 2016 Memorandum from the Division of Trading and Markets regarding a May 16, 2016, telephonic meeting with representatives of Brean Capital, LLC
May 12, 2016 Memorandum from the Division of Trading and Markets regarding a May 12, 2016, meeting with representatives of the Bond Dealers of America
Apr. 18, 2016 Memorandum from the Division of Trading and Markets regarding an April 15, 2016, meeting with representatives of Nomura
Apr. 12, 2016 Memorandum from the Division of Trading and Markets regarding an April 12, 2016, meeting with representatives of the Federal Home Loan Bank of Atlanta and CoBank
Mar. 21, 2016 Memorandum from the Division of Trading and Markets regarding a March 21, 2016, meeting with representatives of Brean Capital, LLC
Mar. 10, 2016 Memorandum from the Division of Trading and Markets regarding a March 10, 2016, meeting with representatives of FINRA
Feb. 29, 2016 Memorandum from the Division of Trading and Markets regarding a February 29, 2016, meeting with representatives of Prudential
Jan. 7, 2016 Memorandum from the Division of Trading and Markets regarding a January 7, 2016, meeting with representatives of Prudential
Jan. 7, 2016 Memorandum from the Division of Trading and Markets regarding a January 7, 2016, meeting with representatives of the Bond Dealers of America
Dec. 11, 2015 Memorandum from the Division of Trading and Markets regarding a December 11, 2015, conference call with representatives of the Securities Industry and Financial Markets Association Asset Management Group
Nov. 25, 2015 Memorandum from the Division of Trading and Markets regarding a November 23, 2015, conference call with representatives of the Treasury Market Practices Group
Nov. 10, 2015 Memorandum from the Office of Commissioner Kara Stein regarding a November 10, 2015, call with representatives of the Mortgage Bankers Association
Nov. 6, 2015 Memorandum from the Division of Trading and Markets regarding a November 6, 2015, meeting with representatives of the Mortgage Bankers Association
Nov. 2, 2015 Memorandum from the Division of Trading and Markets regarding a November 2, 2015, meeting with representatives of SIFMA

 

http://www.sec.gov/comments/sr-finra-2015-036/finra2015036.shtml

Modified: 09/13/2021