Calling All Small Firms: Share Your Feedback
by Mark T. Kim, Chief Executive Officer
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Mark T. Kim Chief Executive Officer | The MSRB issued a request for information (RFI) to solicit feedback from market participants and the public on the impact of municipal market regulation on small firms operating in the municipal securities market. We are seeking this input as a part of broader stakeholder engagement to hear directly from market participants on how any MSRB rules, or lack thereof, may create negative or other unintended consequences related to regulatory, compliance, operational or administrative burdens. The MSRB’s request for information directs a number of questions to smaller municipal advisor firms and dealers in particular, but the MSRB welcomes responses from other market participants on how the MSRB can address any disproportionate costs or burdens on small firms associated with compliance with MSRB Rules. Comments are due to be submitted by February 26, 2024. Partly in response to your feedback that small firms may have unique needs and challenges, the MSRB established a new small firm contact as a resource for you to direct your questions and concerns. As we continue considering your valuable comments, we encourage you to reach out to our dedicated contact with any additional thoughts. Carol Converso |
MSRB Makes Filing with SEC
On Thursday, December 14, the MSRB filed proposed amendments to MSRB Rule G-12, on uniform practice, to promote the completion of allocations, confirmations, and affirmations by the end of trade date for municipal securities transactions between brokers, dealers and municipal securities dealers and their institutional customers to facilitate the move to a settlement cycle of one business day. The MSRB is requesting that the proposed rule change be approved with a compliance date of May 28, 2024, to align with the compliance date for amended Exchange Act Rule 15c6-1 and new Exchange Act Rule 15c6-2.
Compliance Calendar
Dealers and municipal advisors should note the following key compliance dates and deadlines.
December 31, 2023 - Last Day for Dealers to Complete Annual Review and Testing of Supervisory Controls
December 31, 2023 - Last Day to Complete Regulatory Element Content for Municipal Securities Representatives and Principals
December 31, 2023 - Last Day for Municipal Advisors to Complete Annual CEO Certification
December 31, 2023-Last Day to Complete Annual Municipal Advisor Continuing Education
January 1, 2024 - Operative Date of New Market Activity Fees For Dealers and Professional Fees For Municipal Advisor
January 1, 2024 - First Day of Form A-12 Annual Affirmation Period
January 31, 2024 - Last Day of Form A-12 Annual Affirmation Period
February 26, 2024 - Last Day to Comment on Request for Information on Impacts of MSRB Rule on Small Firms
March 1, 2024 - Compliance Date for Newly Adopted MSRB Rule G-46, on Core Standards for Solicitor Municipal Advisors
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