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[…]

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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