I’m On the Outside Looking In: Odd Lots

At a conference that I attended recently, the topic of odd lots came up.

“What is the future of odd lots?”, was the question posed. And, how are they trading versus round lots?

One reply was that trade reports indicate that there’s not much difference between the inter-dealer trade price of a $50m piece and a $1mm piece of that same cusip. The difference occurs in the markup charged to the retail investor, versus the price that an institutional buyer pays for the block. A suggested result of this disparity will be the re-allocation of odd lots into SMA accounts.

Retail will still own the smaller pieces, and the lack of mark-up will cause the data to show less disparity in the prices that retail and institutional customers pay. Problem solved.

I’m on the outside, looking in, but I wonder, will this new business model really represent Best Execution? A one-time markup on a bond may cost less, over time, than the annual fee that will be charged to “manage” that bond over the many years until it matures.

For example, a retail investor that purchases a 10m piece of a bond at 92, with the rep working for $15 per bond, pays a commission of $150. This represents a 1.65% markup on the bond (assuming that the PMP was 90.50).

If that same bond is placed into an SMA account, it will pay a 1% fee every year until it matures, which could be ten, twenty, or more years.

Current examinations being done by regulators, looking into how firms are complying with the MSRB’s Rule G-18, Best Execution, (and G-15 and G-30, Mark-up, and PMP) may cause firms to avoid the appearance of “bad behavior” on their part by discontinuing the use mark-ups as a way to generate revenue.

This solution of taking the easy way out (by not having to explain the mark-up to the customer, or to a regulator) may not the “best execution” that the customer deserves.

Being on the outside, looking in, I welcome any comments, corrections, criticisms, or elucidation on this topic.

Takeaways from Sifma Meet the Regulators 10.1.18

At a roundtable discussion sponsored by SIFMA and held at the offices of Morgan Lewis in Washington DC, and then over a working lunch, various representatives from FINRA, the SEC, and the MSRB met with industry member firms to offer insights into recent regulatory issues and findings. The following is a brief summary of those comments. I would be glad to discuss any of the topics in more detail with those who wish to contact me.

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MSRB asks for comments on Syndicates

The MSRB is asking for comments on Draft Amendments to MSRB Rules on Primary Offering Prices. The Notice, 2018-15, asks for responses by 9.17.18.

There are three topics covered in the request; free-to-trade wires, additional information for the issuer, and the timeframe of payments of group net sales credits (to align them with the payment of net designated credits).

What’s Prevailing with Prevailing Market Price?

What’s Prevailing with Prevailing Market Price (PMP)

In 2014, when Malcolm Northam, then the head of Market Regulation for FINRA, spoke in front of the St. Louis Municipal Bond Club Outing and asked the question “Has everyone here read the SEC’s “Report on the Municipal Securities Market?”(July 31, 2012), very few hands were raised. But there’s no doubt that there’s been a lot more attention paid to the report since “Mac” challenged the room; many of the recommendations made by the SEC in their report have since been answered by the MSRB in the form of both new rules, and changes to existing rules. Outing members would have had to read no further than the Executive Summary (the first ten pages) to understand the changes that were to come.

This article is my take on various sections of rule changes that Dealers should keep in mind when developing their WSPs as regards to “mark-up”. While the rule has already gone into effect (May 14 2018), there are still many details that Dealers are working on in order to make sure that they have correctly interpreted the Rule.

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