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Compliance Resource
Publication date:
Compliance Resource
Publication date:
Information for:

Issuers, Municipal Advisors

Rule Number:

Rule G-42

Notice 2016-11 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

1.  American Bankers Association: Letter from Cristeena G. Naser, Vice President, Center for Securities, Trust and Investments, dated May 27, 2016

2.  American Governmental Financial Services Company: E-mail from Robert Doty dated May 31, 2016

3.  Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated May 27, 2016

4.  Breena LLC: E-mail from G. Letti dated March 28, 2016; and e-mail from G. Letti dated May 1, 2016

5.  Caine Mitter & Associates Incorporated: E-mail from Thomas Caine dated May 27, 2016

6.  Cavanal Hill Investment Management: E-mail from Douglas Benton dated May 2, 2016

7.  Charles Schwab Investment Management: Letter from Marie Chandoha, President and Chief Executive Officer, dated May 27, 2016

8.  Dixworks LLC: E-mail from Dennis Dix, Jr. dated March 29, 2016

9.  George K. Baum & Company: Letter from Guy E. Yandel, Executive Vice President; Dana L. Bjornson, Executive Vice President and Chief Compliance Officer; and Andrew F. Sears, Executive Vice President and General Counsel; dated May 26, 2016

10.  Government Finance Officers Association: Letter from Emily Brock, Director, Federal Liaison Center, dated May 27, 2016

11.  Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated May 27, 2016

12.  Kane, McKenna Capital, Inc.: Letter from Philip R. McKenna, President, dated April 7, 2016

13.  Lawrence Financial Consulting LLC: E-mail from Tom Lawrence dated March 30, 2016; and letter from Tom Lawrence, President, dated May 2, 2016

14.  Lewis Young Robertson & Burningham: Letter from Laura D. Lewis, Principal, dated May 26, 2016

15.  National Association of Bond Lawyers: Letter from Kenneth R. Artin, President, dated May 27, 2016

16.  National Association of Health and Educational Facilities Finance Authorities: Letter from Donna Murr, President; Martin Walke, Advocacy Committee Chairman; and Charles Samuels, General Counsel; dated May 26, 2016

17.  National Association of Municipal Advisors: Letter from Terri Heaton, President, dated May 26, 2016

18.  National Association of State Treasurers: Letter

19.  National Federation of Municipal Analysts: Letter from Lisa Washburn, Chair, dated May 23, 2016

20.  Public Financial Management, Inc,: Letter from Leo Karwejna, Chief Compliance Officer, and Cheryl Maddox, General Counsel, dated May 26, 2016

21.  Public Resources Advisory Group: Letter from Marianne F. Edmonds, Senior Managing Director, dated May 27, 2016

22.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated May 26, 2016

23.  Securities Industry and Financial Markets Association, Asset Management Group: Letter from Timothy W. Cameron, Asset Management Group - Head, and Lindsey W. Keljo, Vice President and Assistant General Counsel, Asset Management Group, dated May 27, 2016

24.  State of Florida, Division of Bond Finance: Letter from J. Ben Watkins III, Director, dated May 27, 2016

25.  Sycamore Advisors, LLC: E-mail from Courtney Tobin dated June 8, 2016

26.  Thomson Reuters: Letter from Michael C. Demas, Head, Municipal Evaluations, dated May 27, 2016

27.  Wake County, North Carolina: Letter from Nicole Kreiser, Debt Manager, dated May 26, 2016

28.  WM Financial Strategies: Letter from Joy A. Howard, Principal, dated May 27, 2016

29.  Wulff, Hansen & Co.: Letter from Chris Charles, President

30.  Zions Bank: Letter from James G. Livingston, Senior Vice President, dated May 25, 2016

   

Compliance Resource
Publication date:
Information for:

Dealers, Municipal Advisors

Rule Number:

Rule G-42

Notice 2015-22 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-12, Rule G-15

1.  Bernardi Securities, Inc.: Letter from Eric Bederman, SVP, Chief Operating & Compliance Officer, dated November 17, 2015

2.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated December 10, 2015

3.  Brandis Tallman LLC: Letter from Richard Brandis

4.  Castle Advisory Company: E-mail from Garth Schulz dated November 10, 2015

5.  Coastal Securities: E-mail from Chris Melton, Executive Vice President, dated December 10, 2015

6.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President & General Counsel, dated December 10, 2015

7.  Geraldine Lettieri: E-mail dated November 10, 2015

8.  Investment Company Institute: Letter from Martin A. Burns, Chief Industry Operations Officer, dated December 1, 2015

9.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated December 10, 2015

 

Notice 2015-18 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-3

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

Notice 2015-10 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

1.  American Governmental Financial Services: E-mail from Robert Doty dated August 24, 2015

2,  Andrew Glassberg: E-mail dated August 17, 2015

3.  Association for Budgeting and Financial Management: Letter from Robert Kravchuk, Chair, et al., dated September 13, 2015

4.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated August 24, 2015

5.  Brandeis University: Letter from Daniel Bergstresser, Associate Professor of Finance, dated September 14, 2015

6.  Coastal Securities: E-mail from Chris Melton, Executive Vice President, dated August 5, 2015

7.  George Mason University: Letter from Jonathan L. Gifford, Professor and Director of Center for Transportation P3 Policy, dated September 1, 2015

8.  John Mousseau: E-mail dated July 29, 2015

9.  Larry Harris: Letter dated September 6, 2015

10.  New York University: Letter from Norman White, Clinical Professor, et al., dated September 16, 2015

11.  Pennsylvania State University: Letter from Patrick J. Cusatis, Associate Professor of Finance, dated September 10, 2015

12.  Securities Industry and Financial Markets Association: Letter from Sean Davy, Managing Director, Capital Markets Division, and David L. Cohen, Managing Director and Associate General Counsel, Municipal Securities Division, dated September 11, 2015

13.  University of Louisville: Letter from James R. Ramsey, President, dated September 4, 2015

Notice 2015-08 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-3

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

Notice 2014-20 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-15

 

1.  Bernardi Securities: Letter from Eric Bederman, Chief Operating and Compliance Officer, dated December 26, 2014

2.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated January 20, 2015

3.  Coastal Securities: Letter from Chris Melton, Executive Vice President, dated January 16, 2015

4.  Consumer Federation of America: Letter from Micah Hauptman, Financial Services Counsel, dated January 20, 2015

5.  DelphX LLC: Letter from Larry E. Fondren, President and CEO, dated January 7, 2015

6.  Diamant Investment Corporation: Letter from Herbert Diamant, President, dated January 9, 2015

7.  Fidelity Investments: Letter from Norman L. Ashkenas, Chief Compliance Officer, Fidelity Brokerage Services, LLC, and Richard J. O'Brien, Chief Compliance Officer, National Financial Services, LLC, dated January 20, 2015

8.  Financial Information Forum: Letter from Darren Wasney, Program Manager, dated January 20, 2015

9.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated January 20, 2015

10.  Financial Services Roundtable: Letter from Rich Foster, Vice President and Senior Counsel for Regulatory and Legal Affairs, dated January 20, 2015

11.  Gerald Heilpern: E-mail dated December 9, 2014

12.  Gerald Heilpern: E-mail dated December 18, 2014

13.  Gerald Heilpern: E-mail dated January 8, 2015

14.  Hilliard Lyons: Letter from Alexander I. Rorke, Senior Managing Director, Municipal Securities Group, dated January 20, 2015

15.  Hutchinson Shockey Erley & Co.: Letter from Thomas E. Dannenberg, President and CEO, dated January 20, 2015

16.  Interactive Data: Letter from Andrew Hausman, President, Pricing and Reference Data, dated January 20, 2015

17.  John Smith: E-mail dated December 10, 2014

18.  Jorge Rosso: E-mail dated November 24, 2014

19.  Karin Tex: Letter dated January 12, 2015

20.  McLiney And Company: Email from George J. McLiney, Jr. dated December 22, 2014

21.  Morgan Stanley Smith Barney LLC: Letter from Vincent Lumia, Managing Director, dated January 20, 2015

22.  Nathan Hale Capital, LLC: Letter from Peter G. Brandel, Senior Vice President, Municipal Bond Trading, and Kenneth T. Kerr, Senior Vice President, Municipal Bond Trading, dated January 20, 2015

23.  Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated January 20, 2015

24.  Private Citizen: E-mail dated November 23, 2014

25.  R. Seelaus & Co., Inc.: Letter from Richard Seelaus dated January 8, 2015

26.  RW Smith & Associates, LLC: E-mail from Paige Pierce dated January 21, 2015

27.  Securities Industry and Financial Markets Association: Letter from Sean Davy, Managing Director, Capital Markets Division, and David L. Cohen, Managing Director and Associate General Counsel, Municipal Securities Division, dated January 20, 2015

28.  Standard & Poor's Securities Evaluations, Inc.: Letter from Gregory Carlin, Vice President, dated January 20, 2015

29.  Thomson Reuters: Letter from Kyle C. Wootten, Deputy Director - Compliance and Regulatory, dated January 16, 2015

30.  Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated January 20, 2015

Notice 2014-18 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors


1.  Anonymous: Letter

2.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated December 8, 2014

3.  Chris Taylor: E-mail dated October 23, 2014

4.  FCS Group: E-mail from Taree Bollinger dated October 24, 2014

5.  Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated December 5, 2014

6.  National Association of Municipal Advisors: Letter from Terri Heaton, President, dated December 8, 2014

7.  PFM Group: Letter from Joseph J. Connolly, Counsel, dated November 7, 2014

8.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated December 8, 2014

Notice 2014-16 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

 

1.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated October 23, 2014

2.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated October 23, 2014

3.  Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated October 23, 2014

4.  Kevin M. Bronner: Letter dated September 27, 2014

5.  Office of the Investor Advocate, United States Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated October 31, 2014

6.  PRISM Municipal Advisors: E-mail from Bradford Sprague dated September 8, 2014

7.  Public Financial Management, Inc.: Letter from John H. Bonow, Chief Executive Officer, dated October 31, 2014

8.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated October 23, 2014

Notice 2014-15 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors


1.  American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated October 1, 2014

2.  Anonymous: E-mail dated October 1, 2014

3.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated October 1, 2014

4.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated October 8, 2014

5.  Caplin & Drysdale: Letter from Trevor Potter and Matthew T. Sanderson dated September 30, 2014

6.  Castle Advisory Company LLC: E-mail from Stephen Schulz dated August 18, 2014.

7.  Center for Competitive Politics: Letter from Allen Dickerson, Legal Director, dated October 1, 2014

8.  Dave A. Sanchez: Letter dated November 5, 2014

9.  Hardy Callcott: E-mail dated September 9, 2014

10.  National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated October 1, 2014

11.  Public Citizen, et. al.: Letter dated October 1, 2014 from Bartlett Naylor, Financial Policy Advocate, and Craig Holman, Government Affairs Lobbyist, Public Citizen; Ron Fein, Legal Director, Free Speech for People; John Harrington, President, Harrington Investments, Inc.; New Progressive Alliance; American Federation of State, County and Municipal Employees; ReFund America Project at the Roosevelt Institute; U.S. PIRG; Consumer Federation of America; and Americans for Financial Reform

12.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 30, 2014

13.  WM Financial Strategies: Letter from Joy A. Howard, Principal, dated October 1, 2014

 

Notice 2014-12 - Request for Comment
Publication date: | Comment due:
Information for:

Municipal Advisors

Rule Number:

Rule G-8, Rule G-9

1.  American Bankers Association: Letter from Cristeena Naser, Vice President, Center for Securities, Trust & Investments, dated August 25, 2014

2.  American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated August 25, 2014

3.  Bart Leary: E-mail dated July 23, 2014

4.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated August 25, 2014

5.  Columbia Capital Management, LLC: Letter from Jeff White, Principal, dated August 25, 2014

6.  Dave A. Sanchez: Letter dated August 25, 2014

7.  Financial Services Roundtable: Letter from Richard Foster, Vice President and Senior Counsel for Regulatory and Legal Affairs, dated August 25, 2014

8.  Florida Division of Bond Finance: Letter from J. Ben Watkins III, Director, dated August 22, 2014

9.  Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated September 2, 2014

10.  Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated August 19, 2014

11.  Lewis Young Robertson & Burningham, Inc.: Letter from Laura D. Lewis, Principal, dated August 25, 2014

12.  National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated August 25, 2014

13.  New York State Bar Association, Business Law Section, Securities Regulation Committee: Letter from Peter W. LaVigne, Chair of the Committee, dated August 27, 2014

14.  Piper Jaffray: Letter from Frank Fairman, Managing Director, Head of Public Finance Services, dated August 25, 2014

15.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated August 25, 2014

16.  Southern Municipal Advisors, Inc.: Letter from Michael C. Cawley, Senior Consultant, dated August 25, 2014

17.  Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated August 25, 2014

18.  WM Financial Strategies: Letter from Joy A. Howard, Principal, dated August 25, 2014

19.  Zions First National Bank: Letter from W. David Hemingway, Executive Vice President, dated August 25, 2014

 

Notice 2014-08 - Request for Comment
Publication date: | Comment due:
Information for:

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

Notice 2014-04 - Request for Comment
Publication date: | Comment due:
Information for:

Municipal Advisors

Rule Number:

Rule G-8, Rule G-9


1.  American Bankers Association: Letter from Cristeena G. Naser, Vice President and Senior Counsel, dated May 1, 2014

2.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated April 28, 2014

3.  Edwin C. Blitz Investments, Inc.: E-mail from Edwin Blitz dated March 18, 2014

4.  Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated April 15, 2014

5.  LIATI Group, LLC: E-mail from Weldon Fleming dated March 10, 2014

6.  MSA Professional Services, Inc.: Letter from Gilbert A. Hantzsch, Chief Executive Officer, dated April 28, 2014

7.  National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated April 28, 2014

8.  Raftelis Financial Consultants, Inc.: Letter from Alexis F. Warmath, Vice President, and Christopher P.N. Woodcock, President, Woodcock & Associates, Inc., dated April 28, 2014

9.  Roberts Consulting, LLC: E-mail from Jonathan Roberts dated March 13, 2014

10.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated April 25, 2014

11.  Tibor Partners Inc.: E-mail from William Johnston dated February 25, 2014

12.  Yuba Group: Letter from Linda Fan, Managing Partner, dated April 28, 2014

 

Notice 2014-01 - Request for Comment
Publication date: | Comment due:
Information for:

Municipal Advisors

Rule Number:

Rule G-8, Rule G-9


1.  Acacia Financial Group, Inc.: Letter from Kim M. Whelan, Co-President, dated March 10, 2014

2.  American Bankers Association: Letter from Cristeena G. Naser, Vice President and Senior Counsel, dated March 4, 2014

3.  American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated March 7, 2014 

4.  American Public Transportation Association: Letter from Michael P. Melaniphy, President and CEO, dated March 10, 2014

5.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated March 10, 2014

6.  Cape Cod Five Cents Savings Bank: Letter from Dorothy A. Savarese, President and Chief Executive Officer

7.  Chancellor Financial Associates: E-mail from William J. Caraway, President, dated January 14, 2014

8.  Coastal Securities: Letter from Chris Melton, Executive Vice President, dated March 10, 2014

9.  College Savings Foundation: Letter from Mary G. Morris, Chair, dated March 10, 2014

10.  College Savings Plans Network: Letter from Betty Everitt Lochner, Director, Guaranteed Education Tuition Program, dated March 10, 2014

11.  Cooperman Associates: Letter from Joshua G. Cooperman dated March 10, 2014

12.  Erika Miller: E-mail dated February 4, 2015

13.  FCS Group: Letter from Taree Bollinger, Vice President, dated March 17, 2014

14.  First River Advisory L.L.C.: Letter from Shelley J. Aronson, President, dated January 16, 2014

15.  First Southwest Company: Letter from Hill A. Feinberg, Chairman and Chief Executive Officer, and Michael G. Bartolotta, Vice Chairman, dated March 7, 2014

16.  Frost Bank: Letter from William H. Sirakos, Senior Executive Vice President, dated March 10, 2014

17.  George K. Baum & Company: Letter from Guy E. Yandel, EVP and Head of Public Finance, Dana L. Bjornson, EVP, CFO and Chief Compliance Officer, and Andrew F. Sears, SVP and General Counsel, dated March 10, 2014

18.  Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liasion Center, dated March 13, 2014

19.  Government Investment Officers Association: Letter from Laura Glenn, President, et. al., dated March 7, 2014

20.  Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated March 4, 2014

21.  J.P. Morgan: Letter from Paul N. Palmeri, Managing Director, dated March 10, 2014

22.  Kutak Rock LLP: Letter from John J. Wagner dated March 10, 2014

23.  Lamont Financial Services Corporation: Letter from Robert A. Lamb, President, dated March 10, 2014

24.  Lewis Young Robertson & Burningham, Inc.: Letter from Laura D. Lewis, Principal, dated March 3, 2014

25.  MSA Professional Services, Inc.: Letter from Gilbert A. Hantzsch, CEO, dated March 10, 2014

26.  National Association of Bond Lawyers: Letter from Allen K. Robertson, President, dated March 18, 2014

27.  National Association of Health and Educational Facilities Finance Authorities: Letter from Pamela Lenane, President, David J. Kates, Chapman and Cutler LLP, and Charles A. Samuels, Mintz Levin, dated March 10, 2014

28.  National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated March 10, 2014

29.  National Healthcare Capital LLC: Letter from Richard Plumstead

30.  New York State Bar Association, Business Law Section, Securities Regulation Committee: Letter from Peter W. LaVigne, Chair of the Committee, dated March 12, 2014

31.  Northland Securities, Inc.: Letter from John R. Fifield, Jr., Director of Public Finance/Senior Vice President, dated March 7, 2014 

32.  Oppenheimer & Co. Inc.: E-mail from John Rodstrom dated March 10, 2014

33.  Parsons Brinckerhoff Advisory Services, Inc.: Letter from Mark E. Briggs, President, dated March 10, 2014

34.  Piper Jaffray: Letter from Frank Fairman, Managing Director, Head of Public Finance Services, dated March 10, 2014

35.  Public Financial Management, Inc.: Letter from John H. Bonow, Chief Executive Officer, dated March 10, 2014

36.  Public Resources Advisory Group: Letter from Thomas Huestis dated March 10, 2014

37.  Raftelis Financial Consultants, Inc.: Letter from Lex Warmath dated March 10, 2014

38.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 10, 2014

39.  Sutherland Asbill & Brennan LLP: Letter from Michael B. Koffler dated March 10, 2014

40.  Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated March 10, 2014

41.  Winters & Co. Advisors, LLC: Letter from Christopher J. Winters dated March 10, 2014

42.  WM Financial Strategies: Letter from Joy A. Howard, Principal, dated March 10, 2014

43.  Woodcock & Associates, Inc.: E-mail from Christopher Woodcock dated January 14, 2014

44.  Wulff, Hansen & Co.: Letter from Chris Charles, President, dated March 17, 2014

45.  Yuba Group: Letter from Linda Fan, Managing Partner, dated March 7, 2014

46.  Zions First National Bank: Letter from W. David Hemingway, Executive Vice President, dated March 10, 2014

 

Compliance Resource
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-12

Notice 2013-19 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-12


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

Notice 2013-14 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-14


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

Notice 2013-06 - Request for Comment
Publication date: | Comment due:
Information for:

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

Notice 2012-63 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors


1.  American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated February 7, 2013

2.  Cooperman Assoc.: E-mail from Josh Cooperman dated December 18, 2012

3.  Financial Information Forum: Letter from Arsalan Shahid, Program Director, dated February 19, 2013

4.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated February 19, 2013

5.  FirstSouthwest: Letter from Hill A. Feinberg, Chairman and Chief Executive Officer, and Michael Bartolotta, Vice Chairman, dated February 19, 2013

6.  Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated March 5, 2013

7.  Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated February 19, 2013

8.  McCarthy, Thomas: E-mail dated December 27, 2012

9.  National Association of Bond Lawyers: Letter from Scott R. Lilienthal, President, dated February 22, 2013

10.  National Federation of Municipal Analysts: Letter from William Oliver, Industry & Media Liaison, dated March 6, 2013

11.  Sanderlin Securities: Letter from Dan Mayfield

12.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated February 19, 2013

13.  Sutherland Asbill & Brennan LLP: Letter from Michael Koffler dated February 19, 2013

14.  Vanguard: Letter from John C. Heywood, Principal, Retail Investor Group, dated February 19, 2013

15.  Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated February 19, 2013

16.  Wells Fargo Securities: Letter from Gerald K. Mayfield, Senior Counsel, dated February 19, 2013

Notice 2012-50 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors


1.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 2, 2012

2.  Dorsey & Company, Inc.: Letter from Steven Rueb, Vice President, dated November 14, 2012

3.  Edward D. Jones & Co., L.P.: Letter from David Fischer-Lodike, Capital Markets & Operations Compliance, dated November 2, 2012

4.  Financial Planning Association: Letter from David A. Cohen, Assistant Director - Government Relations, dated November 2, 2012

5.  Government Finance Officers Association: Letter from Susan Gaffney, Director, Federal Liaison Center, dated November 5, 2012

6.  Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated November 2, 2012

7.  National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated November 2, 2012

8.  Rhode Island Health and Educational Building Corporation: Letter from Robert E. Donovan, Executive Director, dated October 15, 2012

9.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated November 2, 2012

10.  Vanguard: Letter from Christopher Alwine, Head of Municipal Bond Group, dated November 2, 2012

Compliance Resource
Publication date:
Information for:

Dealers, Municipal Advisors

Rule Number:

Rule G-37

Compliance Resource
Publication date:
Information for:

Dealers, Issuers, Municipal Advisors

Rule Number:

Rule G-37

Compliance Resource
Publication date:
Information for:

Dealers, Municipal Advisors, Municipal Fund Securities