Regulatory Notice 14-02

FINRA Requests Comment on Proposed Amendments to FINRA Rule 4210 for Transactions in the TBA Market

Comment Period Expires: February 26, 2014

Executive Summary

FINRA is seeking comment on proposed amendments to FINRA Rule 4210 to establish margin requirements for transactions in the To Be Announced (TBA) market. The proposal, designed to reflect the growth of the TBA market and to replace current interpretive materials under Rule 4210 that have become outdated, is informed by the set of best practices adopted by the Treasury Market Practices Group (TMPG) of the Federal Reserve Bank of New York (FRBNY). Consistent with the overarching goal of many regulatory initiatives since the financial crisis, the proposal aims to reduce counterparty credit risk. The proposal would accomplish this in the TBA market by addressing, among other things, maintenance margin and variation (also referred to in the proposed rule language and this Notice as mark to market) margin requirements, risk limit determinations, concentrated exposures, and exemptions for de minimis transfer amounts and for transactions cleared through registered clearing agencies. The proposed rule amendment is available as Attachment A at


Questions regarding this Notice should be directed to:


  • Glen Garofalo, Director, Credit Regulation, at (646) 315-8464;
  • Peter Tennyson, Director, Broker-Dealer Operations and Financial Responsibility, at (646) 315-8403;
  • Adam H. Arkel, Associate General Counsel, Office of General Counsel, at (202) 728-6961.


The comment period has been extended to March 28, 2014.

View Full Notice PDF 101 KB

The views, expressions, findings and opinions expressed in the comments on this Web page are solely those of the author(s) and FINRA accepts no responsibility for the content of the comments.

Comments By Date Received
Coastal Securities (PDF 78 KB) 2/24/2014
Ambassador Financial Group (PDF 41 KB) 3/13/2014
FirstSouthwest (PDF 38 KB) 3/20/2014
Brean Capital, LLC (PDF 219 KB) 3/21/2014
Pershing LLC (PDF 86 KB) 3/27/2014
Association of Institutional INVESTORS (PDF 347 KB) 3/27/2014
Investment Company Institute (PDF 173 KB) 3/27/2014
Brevan Howard Investment Products Ltd. (PDF 2,467 KB) 3/27/2014
SIFMA Asset Management Group (PDF 96 KB) 3/28/2014
Bond Dealers of America (PDF 414 KB) 3/28/2014
Financial Information Forum (PDF 365 KB) 3/28/2014
BB&T Securities (PDF 1,342 KB) 3/28/2014
Duncan-Williams, Inc. (PDF 1,667 KB) 3/28/2014
Sandler O'Neill & Partners, L.P. (PDF 878 KB) 3/28/2014
MBA (PDF 217 KB) 3/28/2014
George K. Baum & Company (PDF 3,277 KB) 3/28/2014
Mischler Financial Group, Inc. (PDF 79 KB) 3/28/2014
Crescent Securities Group, Inc. (PDF 420 KB) 3/28/2014
G.X. Clarke & Co. (PDF 691 KB) 3/28/2014
SIFMA (PDF 121 KB) 3/28/2014
Credit Suisse Securities (PDF 2,510 KB) 3/28/2014
Robert W. Baird & Co. (PDF 112 KB) 3/28/2014
MountainView Securities, LLC (PDF 180 KB) 3/28/2014
Shearman & Sterling LLP (PDF 1,054 KB) 3/28/2014
PIMCO (PDF 308 KB) 3/28/2014
Simmons First Investment Group, Inc. (PDF 67 KB) 3/31/2014
Vining Sparks, IBG, LP (PDF 216 KB) 3/31/2014
MetLife (PDF 64 KB) 4/2/2014
FHLBI (PDF 161 KB) 4/7/2014