SEC Adopts Amendments to Rule 15c2-12 to Improve Municipal Securities Disclosure

In August 2018, the U.S. Securities and Exchange Commission (the “SEC”) announced that it has adopted amendments to Rule 15c2-12 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), in an effort to enhance transparency in the municipal securities market. The SEC has stated that the commission believes the amendments will provide[…]

MSRB Reminds Municipal Advisors of September Deadline to complete Series 50 Exam

As summarized below, the MSRB recently issued a reminder to remind member firms that engage in municipal advisory activities of the obligation to ensure that every Associated Person with your firm that engages in municipal advisory activities is appropriately qualified. Specifically, Associated Persons who engage in municipal advisory activities on behalf of a municipal advisor firm is required to be qualified as a “municipal advisor representative” by passing the Municipal Advisor Representative Qualification Examination (Series 50 exam). Read More…

Recent Revisions to MSRB Rule G-14

On May 22, 2015, the Securities and Exchange Commission (SEC) approved certain amendments to MSRB Rule G-14 related to transaction reporting, which became effective on July 18, 2016.  MSRB Rule G-14 requires dealers to report all executed transactions in most municipal securities to the MSRB’s Real-Time Transaction Reporting System (RTRS) within 15 minutes of the time of trade, with limited exceptions.  RTRS serves the dual objectives of price transparency and market surveillance.  The MSRB makes transaction data for transparency purposes available to the Read More…

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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