From: Paul Scheurer
How will a customer know whether or not the prevailing market price was used to determine the mark-up/mark-down of a debt security?
If a broker-dealer uses a method other than contemporaneous cost, the dealer should be required to alert the customer to that fact. Then the customer can inquire further, thus balancing "caveat emptor" against the "caveat vendor" policy of the federal securities laws.
I suggest expanding IM-2440-2 to require that transaction tickets for such debt securities be stamped: "Dealer cost NOT used to determine mark-up or mark-down. Details disclosed on request."