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[…]

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[…]

MSRB announces Interpretive Notice re: Time of Trade Disclosure

MSRB Rule G-47, as it relates to time of trade disclosure, requires firms to disclose, at or prior to the time of trade, all material information known about the transaction, as well as material information about the municipal security that is reasonably accessible to the market. The MSRB has previously provided interpretive guidance on specific types of information that is material where specific scenarios occur and requires time of trade disclosure, and recently published a notice to state its interpretation that the fact that a municipal security Read More…

MSRB Revises Content Outline for Series 50 Exam

In June 2016, the Municipal Securities Rulemaking Board (MSRB) filed a proposed rule change with the Securities Exchange Commission (SEC) to revise the content outline for the Municipal Advisor Representative Qualification Examination (Series 50 exam). The content outline for the Series 50 exam has been amended to reflect changes to the laws, rules and regulations covered by the examination. These amendments also, among other things, incorporate the functions and associated tasks performed by a municipal advisor representative.

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MSRB Rule G-18: Best Execution

MSRB Rule G-18, the new best-execution rule for municipal securities, became effective March 21, 2016. At this point, most broker-dealers registered with the Municipal Securities Rulemaking Board (“MSRB”) have implemented written policies and procedures for seeking best execution on customer orders in municipal securities. Now, if you are a compliance officer or municipal securities principal at one of these broker-dealers, you may still be pondering precisely how your firm is going to perform and document the required periodic reviews of its best-execution policies and procedures. Many introducing broker-dealers hope to avail themselves of a provision in Rule G-18 that seemingly permits them to rely on the best-execution reviews of their clearing firms. In this blog post, we identify the conditions for obtaining this relief and discuss some of the challenges of relying on another broker-dealer’s best-execution reviews.

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Minimum Denominations for Municipal Securities

Regulators are focusing their attention on municipal securities firms that effect transactions in municipal securities in an amount lower than the minimum denomination of the issue. Several broker-dealers have been fined for their failure to comply with such minimum denominations.

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