Select regulatory documents by category:
1. Bartholomew, Patricia E., 2014 Chair, Securities Industry Council on Continuing Education, and Bartol, William E., 2013 Chair, Securities Industry Council on Continuing Education: Letter dated January 13, 2014
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated January 13, 2014
3. Diamant Investment Corporation: E-mail from Herbert Diamant dated December 13, 2013
4. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated January 13, 2014
5. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated January 13, 2014
6. MetLife Securities, Inc.: Letter from Jennifer Lewis, Corporate Counsel, dated January 13, 2014
7. National Society of Compliance Professionals: Letter from Judy Werner, Executive Director, dated January 14, 2014
8. Romano Wealth Management: E-mail from Joe Romano dated January 13, 2014
9. RW Smith & Associates, Inc.: E-mail from Paige Pierce dated January 13, 2014
10. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated January 13, 2014
11. Wulff, Hansen & Co.: Letter from Chris Charles, President, dated January 9, 2014
Bank Dealers, Dealers, Municipal Advisors
1. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated September 20, 2013
2. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated September 20, 2013
3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 20, 2013
4. U.S. Bancorp Investments, Inc.: E-mail from Herbert Neufeld dated August 19, 2013
1. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated September 20, 2013
2. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated September 20, 2013
3. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated September 20, 2013
4. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated September 20, 2013
5. Wells Fargo Securities: Letter from Gerald K. Mayfield, Senior Counsel, dated September 20, 2013
Bank Dealers, Dealers
1. Ambassador Financial Group: E-mail from Allen Collins dated August 8, 2013
2. Barclays Capital Inc.: Letter from Jennifer Small, Municipal Compliance, dated October 7, 2013
3. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated October 7, 2013
4. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated October 7, 2013
5. Interactive Data Corporation: Letter from Mark Hepsworth, President, Interactive Data Pricing and Reference Data, dated October 7, 2013
6. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated September 20, 2013
7. J.J.B. Hilliard, W.L. Lyons LLC: Letter from Alex Rorke, Director, Public Finance
8. Melton, Chris: Letter dated September 26, 2013
9. Private Investor: E-mail from Private Investor dated September 2, 2013
10. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated October 7, 2013
11. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated October 7, 2013
Bank Dealers, Dealers, Municipal Advisors
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 1, 2013
2. Corporate Treasury Investment Consulting LLC: Letter from Mark O. Conner, Principal, dated August 16, 2013
3. Financial Information Forum: Letter from Manisha Kimmel, Executive Director, dated November 1, 2013
4. Interactive Data Corporation: Letter from Mark Hepsworth, President, Interactive Data Pricing and Reference Data, dated November 1, 2013
5. Leonard, Jack: Letter dated August 1, 2013
6. Long, Cate: E-mail dated November 1, 2013
7. Sayer, Steven: E-mail dated November 3, 2013
8. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated November 1, 2013
9. Wells Fargo Advisors, LLC: Letter from Robert J.McCarthy, Director of Regulatory Policy, dated November 1, 2013
Bank Dealers, Dealers
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated June 12, 2013
2. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated June 12, 2013
3. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated June 12, 2013
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated May 6, 2013
2. College Savings Foundation: Letter from Roger Michaud, Chairman, dated May 6, 2013
3. College Savings Plans Network: Letter from Michael L. Fitzgerald, Treasurer of Iowa and Chairman, dated May 6, 2013
4. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated May 6, 2013
5. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated May 5, 2013
6. Retail Investor: Email from Retail Investor dated August 25, 2013
7. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated May 6, 2013
8. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated May 6, 2013
Bank Dealers, Dealers, Municipal Advisors
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated March 28, 2013
2. Boyle, Nick: Letter
3. City of Milwaukee: E-mail from Richard Li dated March 7, 2013
4. Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated April 30, 2013
5. National Association of Bond Lawyers: Letter from Scott R. Lilienthal, President, dated March 29, 2013
Bank Dealers, Dealers
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated March 12, 2013
2. Charles Schwab & Co., Inc.: Letter from Michael P. Moran, Vice President, Compliance, dated March 12, 2013
3. Lumesis, Inc.: Letter from Gregg L. Bienstock, Co-Founder and Chief Executive Officer, dated March 11, 2013
4. Lumesis, Inc.: Letter from Gregg L. Bienstock, Co-Founder and Chief Executive Officer, dated July 17, 2013
5. R.W. Smith & Associates, Inc.: E-mail from Paige Pierce dated March 20, 2013
6. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated March 12, 2013
7. TMC Bonds, L.L.C.: Letter from Thomas S. Vales, Chief Executive Officer, dated March 11, 2013
8. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated March 12, 2013
Bank Dealers, Dealers
1. Barclays Capital Inc.: Letter from Scott Coya, Director, Municipal Compliance, dated March 15, 2013
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated March 15, 2013
3. Charles Schwab & Co. Inc.: Letter from Michael P. Moran, Vice President, Fixed Income Compliance, dated March 15, 2013
4. Eastern Bank: E-mail from James N. Fox, SVP and Managing Director, dated March 15, 2013
5. Financial Information Forum: Letter from Arsalan Shahid, Program Director, dated March 15, 2013
6. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated March 15, 2013
7. Frost Bank: Letter from Robert N. Jacobs, Assistant Vice President/Compliance Officer, dated March 11, 2013
8. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel-Securities Regulation, dated March 15, 2013
9. J.W. Korth & Company LP: E-mail from James Korth dated March 14, 2013
10. R.W. Smith & Associates, Inc.: E-mail from Paige Pierce, dated March 20, 2013
11. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 15, 2013
12. Seidel & Shaw, LLC: Letter from Thomas W. Shaw, President, dated March 15, 2013
13. Standish: E-mail from Daniel Rabasco dated March 15, 2013
14. TMC Bonds, L.L.C.: Letter from Thomas S. Vales, Chief Executive Officer, dated March 15, 2013
15. Tradition Asiel Securities, Inc.: Letter from Eric M. Earnhardt, Chief Compliance Officer, dated March 19, 2013
Previously Registered Entitites
Previously registered entitites. Thank you for your letter [name and date deleted] which has been referred to me for response. The letter relates to the Municipal Securities Rulemaking Board's rule A-12, which imposes an initial fee of $100 on municipal securities brokers and municipal securities dealers.
We note that the terms "municipal securities broker" and "municipal securities dealer" are not restricted under the Securities Acts Amendments of 1975 (the "1975 Amendments") to securities firms and banks effecting transactions exclusively in municipal securities. Many municipal securities brokers and municipal securities dealers (other than bank dealers) were registered with the Securities and Exchange Commission (the "Commission") as brokers or dealers prior to the 1975 Amendments. Municipal securities brokers and municipal securities dealers already registered with the Commission were not required to re-register with respect to their municipal securities activities, but nevertheless are subject to payment of the Board's initial fee. In addition, many municipal securities brokers and municipal securities dealers have been and are members of the national securities exchanges and the National Association of Securities Dealers, Inc.
We are unable to conclude from the information set forth in your letter that the initial fee imposed by the Board's rule A-12 is inapplicable to your firm. MSRB interpretation of June 16, 1976.
Interpretive Notice on Underwriting Assessment
The Municipal Securities Rulemaking Board (the “Board”) has received several requests for interpretation of rule A-13, which requires each municipal securities broker and municipal securities dealer to pay the Board a fee [on] … the face amount of municipal securities purchased from an issuer as part of a new issue. These requests concern the applicability of the fee to securities which have a stated maturity of [nine months or less], but are part of a new issue having a final stated maturity of [more than nine months]. Rule A-13 is intended to impose the … underwriting assessment on the face amount of all securities purchased from an issuer that are part of a new issue of municipal securities if any part of the issue has a final stated maturity of [nine months or less]… from the date of the securities. Thus, calculation of the fee should be based upon all municipal securities which are part of such new issue, including securities having a stated maturity of [nine months or less]. The assessment is not intended to apply, however, to short-term issues having a final maturity of [nine months or less].
NOTE: Revised to reflect subsequent amendments.
