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[…]