Select regulatory documents by category:
Bank Dealers, Dealers, Municipal Advisors
All Comments to Notice 2020-02
1. Acacia Financial Group, Inc.: Letter from Kim M. Whelan, Co-President, and Noreen P. White, Co-President, dated April 29, 2020
2. Action Center on Race and the Economy, AFSCME, AFL-CIO, Americans for Financial Reform Education Fund, Consumer Federation of America and Public Citizen: Letter dated April 29, 2020
3. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated April 29, 2020
4. Government Finance Officers Association: Letter from Emily Swenson Brock, Director, Federal Liaison Center, dated April 29, 2020
5. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated April 15, 2020
6. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated April 29, 2020
7. National Association of State Auditors, Comptrollers and Treasurers: Letter from Beth Pearce, President, dated April 30, 2020
8. National Association of State Treasurers: Letter from Shaun Snyder, Executive Director, dated April 28, 2020
9. National Federation of Municipal Analysts: Letter from Nicole Byrd, Chair, dated April 29, 2020
10. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Bernard V. Canepa, Vice President and Assistant General Counsel, dated April 29, 2020
11. Steve Apfelbacher, Renee Boicourt, Marianne Edmonds, Robert Lamb, Nathaniel Singer and Noreen White [former MSRB Board members]: Letter dated April 29, 2020
Bank Dealers, Dealers, Municipal Advisors
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 19, 2015
2. National Association of Municipal Advisors: Letter from Terri Heaton, President, dated November 19, 2015
3. Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated October 29, 2015
4. Securities Industry Financial Markets Association: Letter from Michael Decker, Managing Director, dated November 19, 2015
5. Stephen Heaney: E-mail dated November 10, 2015
Bank Dealers, Dealers, Municipal Advisors
1. Americans for Financial Reform; American Federation of State, County and Municipal Employees; and Consumer Federation of America: Letter dated July 13, 2015
2. Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated July 20, 2015
3. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel--Securities Regulation, dated July 13, 2015
4. Jay M. Goldstone: Letter dated July 10, 2015
5. Jerry Gold: Letter dated July 17, 2015
6. Lamont Financial Services Corporation: Letter from Bob Lamb, President, dated July 7, 2015
7. Loews Corporation: Letter from Mark G. Muller dated July 1, 2015
8. National Association of Municipal Advisors: Letter from Terri Heaton, President, dated July 13, 2015
9. National Federation of Municipal Analysts: Letter from Lisa S. Good, Executive Director, dated July 13, 2015
10. Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated July 13, 2015
11. Robert E. Rutkowski: E-mail dated July 13, 2015
12. Robert Zubak: Letter dated July 6, 2015
13. Samson Capital Advisors: Letter from Benjamin S. Thompson, Managing Principal and Chief Executive Officer, dated July 7, 2015
14. Securities Industry and Financial Markets Association: Letter from Michael Decker, Managing Director, dated July 13, 2015
15. Wells Capital Management Incorporated: Letter from Gilbert L. Southwell III, Vice President, dated July 8, 2015
Bank Dealers, Dealers, Municipal Advisors
1. Arrow Partners: Letter from Steven Rubenstein dated May 16, 2014
2. Association of Registration Management: Letter from Michele Van Tassel, President, dated May 16, 2014
3. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated May 16, 2014
4. Cedar Partners Ltd: Letter from Christy Ping, Director/Chief Compliance Officer, dated May 16, 2014
5. Central States Capital Markets: E-mail from Mark Detter dated April 17, 2014
6. CFA Institute: Letter from Inigo Bengoechea, Director, and Dan Larocco, Manager, dated April 25, 2014
7. Compass Securities Corporation: Letter from John R. Ahern, President
8. Dixworks LLC: E-mail from Dennis Dix, Jr. dated April 11, 2014
9. Fitzgibbon Toigo Associates, LLC: E-mail from Brian X. Fitzgibbon dated May 16, 2014
10. Fortress Group, Inc.: Letter from Bruce A. Williamson, Managing Director and Chief Compliance Officer, dated May 16, 2014
11. Frank Taylor: E-mail dated March 19, 2014
12. George K. Baum & Company: Letter from Guy E. Yandel, EVP Public Finance, Dana L. Bjornson, EVP and Chief Compliance Officer, and Andrew F. Sears, SVP and General Counsel, dated May 16, 2014
13. Government Credit Corporation: E-mail from Joseph Mooney dated March 18, 2014
14. Hamersley Partners, LLC: Letter from Andrew Phillips, Principal and CCO, dated May 16, 2014
15. IMMS LLC: E-mail from John Daly dated May 16, 2014
16. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated May 8, 2014
17. Jorge Rosso: E-mail dated April 3, 2014
18. Monahan & Roth, LLC: Letter from Lisa Roth, President, dated May 16, 2014
19. MVision Private Equity Advisers USA LLC: Letter from Victoria Sherliker, General Counsel, dated May 16, 2014
20. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated May 16, 2014
21. New Albany Capital Partners, LLC: Letter from Rick Wayman dated May 14, 2014
22. Oyster River Capital LP: Letter from Richard A. Murphy dated May 16, 2014
23. Perkins Fund Marketing LLC: Letter from Gilman C. Perkins, Principal and Managing Member, dated May 16, 2014
24. Raftelis Financial Consultants, Inc.: Letter from Alexis F. Warmath, Vice President, and Christopher P.N. Woodcock, President, Woodcock & Associates, Inc., dated May 16, 2014
25. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated May 16, 2014
26. Sonja Sullivan: E-mail dated May 16, 2014
27. Stacy Havener: E-mail dated May 16, 2014
28. Stonehaven: Letter from Steven Jafarzadeh, Managing Director and Partner, dated May 16, 2014
29. Tessera Capital Partners: Letter from Donna DiMaria, CEO/CCO, dated May 16, 2014
30. Third Party Marketers Association: Letter from Donna DiMaria, Chairman of the Board of Directors, dated May 16, 2014
31. Tibor Partners Inc.: E-mail from William Johnston dated March 18, 2014
32. Timothy D. Wasson: Letter
33. Yuba Group: Letter from Linda Fan, Managing Partner, dated April 28, 2014
34. Zions First National Bank: Letter from W. David Hemingway, Executive Vice President, dated May 16, 2014
35. Zions First National Bank: Letter from James G. Livingston, Senior Vice President, dated May 16, 2014
Execution of Infrequent Unsolicited Orders
Execution of infrequent unsolicited orders. This is in response to your letter in which you state that your firm is a discount broker that executes orders on an unsolicited basis and that occasionally a customer will approach your firm to sell a municipal security they own or to purchase a specific issue. You ask that the Board give consideration to allowing a firm like yours to act as a broker/dealer for customers on an unsolicited basis without being required to have an associated person qualified as a municipal securities principal.
Rule G-2, on standards of professional qualification, states that no dealer shall effect any transaction in, or induce or attempt to induce the purchase or sale of, any municipal security unless such dealer and every natural person associated with such dealer is qualified in accordance with the rules of the Board. Rule G-3, on professional qualifications, states that a dealer that conducts a general securities business shall have at least one associated person qualified as a municipal securities principal to supervise the dealer’s municipal securities activities.
The Board’s rules do not provide an exemption from the numerical requirements for municipal securities principals based on the type of transactions in municipal securities in which a dealer engages. There also is no exemption from the Board’s rules based on a de minimus number of transactions in municipal securities. MSRB interpretation of October 2, 1998.
