The SEC recently approved FINRA’s rule change to permit dissemination of trade data for 144A bonds on TRACE (see: http://www.sec.gov/rules/sro/finra/2013/34-70345.pdf). FINRA will publish a regulatory notice within 60 days of the rule approval, which was earlier this month, providing additional details. As we previously reported in an earlier post, the relaxation of the prohibition on general solicitation mandated by the JOBS Act made the decision to disseminate trade data for 144A deals simpler.
Certain dissemination caps (applicable now to bond deals) will apply – $5 million for Investment Grade corporate bonds and $1 million for Non-Investment Grade – to Rule 144A corporate bond transactions. As a result, the size of a Rule 144A Investment Grade corporate bond transaction in excess of $5MM would be displayed as “$5MM+” and the size of a Rule 144A Non-Investment Grade corporate bond transaction in excess of $1MM would be displayed “$1MM+.”