Rule 4530

Rule 4530 Product and Problem Codes and Filing Application Form to reflect changes related to the DOL’s fiduciary rule

FINRA announced that it has revised the Rule 4530 (Reporting Requirements) Product and Problem Codes and Filing Application Form to reflect changes related to the Department of Labor’s fiduciary rule and the MSRB’s rules on customer complaints and recordkeeping. The changes related to the DOL’s fiduciary rule became effective on June 9, 2017, while the changes related to the MSRB’s customer complaints rules will take effect on October 1, 2017.  Read More…

Solicitor Municipal Advisors Rules

As summarized below, the MSRB recently provided guidance regarding the application of several of the most important MSRB rules applicable to municipal advisors that undertake the solicitation of a municipal entity or obligated person.  Because much of the content of this notice applies to municipal advisors generally, the guidance provided may be useful to non-solicitor municipal advisors as well. Read More…

T+2 Settlement Cycle for Transactions in Municipal Securities

As summarized below, the MSRB recently announced the effective date of amendments to MSRB Rules G-12, on uniform practice, and G-15, on confirmation, clearance, settlement and other uniform practice requirements with respect to transactions with customers, to define regular-way settlement for municipal securities transactions as occurring on a two-day settlement cycle (T+2). The SEC approved the MSRB’s proposal to make these rule amendments and other technical amendments in April 2016 and the effective date will be September 5, 2017. Read More…

MSRB Requests Comment on Draft Amendments to MSRB Rule G-34

As summarized below, the Municipal Securities Rulemaking Board (MSRB) recently published a Regulatory Notice seeking comment on draft rule amendments to MSRB Rule G-34, on CUSIP numbers, new issue, and market information requirements, to clarify existing application of the rule to certain new issue municipal securities, and to expand the application of the rule to certain additional industry participants. In addition, the MSRB also wanted to remind firms of their existing obligation under Rule G-34(b) to obtain CUSIP numbers for certain secondary market securities. Read More…

MSRB requests comment on draft amendments to MSRB Rule G-26 on Customer Account Transfers

The MSRB is requesting comment on draft amendments to MSRB Rule G-26 related to customer account transfers. The draft amendments are primarily designed to modernize the rule and promote a uniform customer account transfer standard for all broker-dealers. Rule G-26 requires broker-dealers to cooperate in the transfer of customer accounts and specifies procedures for carrying out the transfer process. Such transfers occur when a customer decides to transfer an account from one broker-dealer, the carrying party to another, the receiving party. The rule establishes specific time frames within which the carrying party is required to transfer a customer account; limits Read more about MSRB requests comment on draft amendments to MSRB Rule G-26 on Customer Account Transfers[…]

The Application of MSRB Rules to Transactions in MSRB Accounts

Registered representatives have increasingly inquired about the application of certain MSRB rules to managed accounts in which a RIA is exercising discretion to buy and sell municipal securities on behalf of the account holder. Specifically, with respect to these transactions, they are expected to: Provide the time-of-trade disclosures required by MSRB Rule G-47 to the ultimate investor, who is the account holder (i.e., the RIA’s client), particularly if the dealer does not know the identity of the investor; and Obtain a customer affirmation from such an investor for purposes of qualifying the person, separately, as a SMMP under MSRB Rule Read more about The Application of MSRB Rules to Transactions in MSRB Accounts[…]