Compliance Tip of the Week 2020
(A weekly newsletter providing compliance tips for regulated entities):
December 14, 2020: Timely Close-Outs
MSRB Rule G-12(h), related to close-outs, establishes a deadline for either cancelling or closing out an inter-dealer transaction. If the transaction cannot be completed, then it should be closed out or cancelled no later than 10 calendar days after settlement date. However, Rule G-12(h)(i)(E) does permit the purchaser to grant the seller a one-time extension for an additional 10 calendar days. Assuming an extension is granted, the maximum time a seller has to deliver the securities or close out an open inter-dealer fail is 20 calendar days.
December 7, 2020: Share Your Input on the MSRB’s Strategic Priorities
The Municipal Securities Rulemaking Board (MSRB) today published a request for input notice on its strategic goals and priorities. Every three to five years, the MSRB engages in a strategic planning exercise to reassess the long-term direction of the organization responsible for safeguarding the integrity of the nearly $4 trillion municipal securities market. The MSRB seeks input on opportunities for the organization to improve its effectiveness, address emerging and evolving market risks, and better serve the municipal market of today and tomorrow. Comments should be submitted no later than January 11, 2021.
November 30, 2020: Amending Form MA-I Information
Are you working on completing your customary year-end checklist? For dealers that are also municipal advisors, remember that if you receive Form U4 amendments from associated persons, those Form U4 amendments will not be automatically reflected on the Form MA-I. You may need add to your checklist the task of going into EDGAR to make corresponding amendments to the Form MA-I information.
November 23, 2020: Update Your Year-End To-Do List
'Tis the season for year-end to-do lists. If your customers and/or municipal advisory clients have yet to receive the requisite annual notification this calendar year, you may want to have Rule G-10 annual notifications on your list. Rule G-10 requires dealers and municipal advisors to provide customers or municipal advisory clients a written notification once every calendar year.
See the G-10 annual notifications reminder notice.
November 16, 2020: Check out Compliance Corner
Check it out the latest issue of Compliance Corner to learn more about volunteering for the MSRB's Compliance Advisory Group, get answers to frequently asked questions about compliance with MSRB Rules G-37 and G-42, or find a compliance tip on completing Form G-32 with respect to an offering that is a private placement. You also can get up to speed on a recent enforcement matter regarding a state-funded Arizona charter school.
November 9, 2020: Zoom Lunch—Gift or Entertainment Expense?
In the current environment of COVID-19 social distancing and remote work, we are all learning to adapt to virtual meetings and events. Under MSRB Rule G-20, on gifts and gratuities, certain types of gifts qualify as "normal business dealings" and are not subject to the $100 gift limit, as long as the conditions under the rule are met. Meals, such as a box lunch or snack, that are sent to an issuer representative and other members of the deal team attending a virtual business meeting hosted by the regulated entity would be excluded from the gift limitation, so long as the cost of the food and beverage, as well as the frequency of such virtual meeting(s), does not raise any question of propriety.
Even if we cannot be together in person, we can still share an occasional meal over Zoom under Rule G-20(d).
November 2, 2020: Respecting Different Perspectives
MSRB Rules G-27 and G-44 are primarily principles-based rules. In creating a compliance program, one size does not fit all. The MSRB recognizes the broad differences among dealers as well as among municipal advisors. No matter the perspective, the common goal is a supervisory system that is reasonably designed to achieve compliance with applicable securities laws and regulations, including applicable MSRB rules.
See MSRB Rule G-27.
See MSRB Rule G-44.
October 26, 2020: Get in the Spirit...Review the MSRB's Systems Holiday Schedule
As the leaves fall, days get shorter, and air outside gets nippy, we are reminded that the holiday season is fast approaching. The MSRB publishes a Systems Holiday Schedule to assist dealers with determining submission deadlines associated with Rule G-14, on transaction reporting, Rule G-32, on disclosures in connection with primary offerings, and Rule G-34 (c), on variable rate security market information.
Review the MSRB's System Status webpage for real-time information on the operational status of the MSRB's market transparency systems.
October 19, 2020: Gearing Up for the Discontinuation of LIBOR
There have been multiple reminders about the switch from LIBOR to the Secured Overnight Financing Rate (SOFR) as the standard U.S. reference rate in the debt and derivatives market. This past weekend the derivatives markets had the "big bang" switch to SOFR. While this "big bang" may not directly affect your firm's municipal securities activities, it is a good reminder that the transition from LIBOR to SOFR continues.
Are you ready?
Read the MSRB's resource about the switch from LIBOR to SOFR.
October 12, 2020: MSRB-Owned Exams Enrollment Windows Extended
In monitoring the COVID-19 pandemic and related risks of operational challenges and market disruption, the MSRB continues to evaluate information related to scheduled and completed MSRB-owned professional qualification examinations at Prometric test centers. That said, individuals who had an exam enrollment window expire after March 16 or have one that will expire before November 16, 2020, have been provided an extension of their exam enrollment window until November 16, 2020. The MSRB will continue to work with FINRA, as its exam administrator, to assess the situation and consider whether any additional extensions are necessary.
See
frequently asked questions related to COVID-19 regulatory relief.
See
FINRA’s Coronavirus Impact on FINRA-Administered Exams webpage.
October 6, 2020: Be Educated on the Fees for 529 Plan Rollovers
A 529 rollover can protect funds contributed by an account owner from tax consequences and other penalties if such funds are rolled over from one 529 savings plan to another state’s 529 savings plan for the same beneficiary or to another 529 savings plan for a different beneficiary, if certain conditions are met. In effectuating a 529 rollover, dealers should be mindful of the associated fees and charges assessed to ensure such fees are appropriate.
Read MSRB Rule G-17: Conduct of Municipal Securities and Municipal
Advisory Activities.
See MSRB Resources for 529 Plans and ABLE Programs.
September 28, 2020: Recognizing the Vital Role of Compliance Professionals
In recognition of Compliance Officer Day, which was celebrated on September 26, the MSRB acknowledges that compliance professionals play a vital role in the regulatory framework. The MSRB provides compliance resources and tools to assist compliance professionals and their firms in complying with MSRB rules that apply to their business and operations.
Compliance is a shared corporate responsibility.
Review MSRB Rule G-27 on dealer supervision.
See MSRB Rule G-44 on supervisory and compliance obligations of
municipal advisors.
September 21, 2020: Use ATS Indicator to Report Inter-Dealer Trades on an ATS
MSRB Rule G-14 requires dealers to report all executed transactions in municipal securities to the MSRB’s Real-Time Transaction Reporting System (RTRS) within 15 minutes of the time of trade, with limited exceptions. As a reminder, dealers executing inter-dealer transactions with or using the services of an alternative trading system (ATS) are to use the ATS special condition indicator when reporting these trades to the RTRS, even if such transactions executed with an ATS were done so as voice trades executed over the phone. In addition, a dealer that fails to accurately report the ATS special indicator will receive an error code (Q55A) when the seller's and buyer's trade reports differ with respect to the ATS special condition indicator.
See the rule.
See additional MSRB guidance on Rule G-14.
September 14, 2020: Virtual Fundraising Events
Brokers, dealers and municipal securities dealers ("dealers"), municipal advisors and dealer-municipal advisors (collectively "regulated entities") are reminded that attendance at a virtual fundraising event (e.g., virtual dinner or rally) for an official of a municipal entity, as part of such official's congressional campaign or otherwise, may trigger a ban on engaging in municipal securities business and/or municipal advisory business with a municipal entity if certain conditions are not met. Specifically, contributions by a municipal finance professional (MFP) or municipal advisor professional (MAP) would not trigger a ban on business if the MFP or MAP who made the contribution is entitled to vote for such official and any contributions to such official made by the MFP or MAP do not exceed, in total, $250 per election. In addition, any MFP or MAP who attends the event for the purpose of soliciting contributions by others for the municipal entity official would violate Rule G-37's prohibition on soliciting contributions.
August 31, 2020: MSRB Resumes Price Variance Alerts for Dealers
As part of the MSRB's COVID-19 pandemic-related regulatory measures, in March, the MSRB temporarily suspended sending price variance alerts to dealers for trades reported to the MSRB's Real-Time Transaction Reporting System (RTRS). As of September 1, 2020, the MSRB will resume the transmission of price variance alerts to dealers when a transaction reported to RTRS by the dealer is at a price that is notably different (i.e., notably lower or higher) than the price reported to RTRS by other dealers in the same security within a specified time period.
As a reminder, price variance alerts are meant to be a tool to assist dealers in identifying transactions that may warrant review to ensure the information reported to RTRS reflects the trade price as intended. Under MSRB Rule G-14, on reports of sales or purchases, dealers have an obligation to submit transaction data that meets the specified format for the RTRS Portal and to promptly review and address any problem or potential problem with such transaction data.
August 24, 2020: Did You Miss the Municipal Advisor Compliance Webinar?
If you missed the virtual Compliance Outreach Program for Municipal Advisors hosted earlier this month by the SEC, FINRA and MSRB, don't worry. You can access all the great content you missed on demand and get CPE credit, as well.
Access the on-demand webinar here.
August 17, 2020: Not Every Underwriting Requires a Public Distribution
MSRB Rule G-32 requires a dealer to complete Form G-32 in a timely and accurate manner when acting as an underwriter, as the term is defined in SEC Rule 15c2-12(f)(8), in a primary offering. Generally, with limited exception, SEC Rule 15c2-12(f)(8) defines an underwriter as a dealer that purchases from an issuer, or offers or sells for an issuer, an offering of municipal securities. This includes dealers having a direct or indirect participation in any such undertaking, or a participation in the direct or indirect underwriting of any such undertaking. Accordingly, an underwriter for purposes of Rule G-32 includes a dealer acting as an underwriter in a primary offering, whether that offering is a public distribution or a private placement (e.g., an exempt limited offering or direct purchase).
August 10, 2020: Inadvertent Political Contributions under MSRB Rule G-37
Were you online and did you inadvertently make a political contribution that would trigger a ban on business with a municipal entity for your firm under Rule G-37?
If the contribution is returned to you within 60 days of your firm's discovery of the contribution, your firm may be able to avail itself of an "automatic" exemption. Rule G-37(j) provides an automatic exemption that allows a firm to continue to do municipal securities business or municipal advisory business with the relevant municipal entity. However, your firm must have discovered the contribution (e.g., through your notification after realizing that a ban may have been triggered or through a quarterly compliance certification relating to political contributions) within four months of the date it was made and the contribution must not have exceeded $250. Additionally, a firm is only entitled to two automatic exemptions per 12-month period and no more than one automatic exemption can relate to contributions by the same person regardless of the time period.
August 3, 2020: MSRB’s Late-Fee Suspension Has Expired
As part of the MSRB's COVID-19 pandemic-related regulatory measures, the MSRB temporarily waived the charging of late fees assessed under Rules A-11 and A-12 (i.e., professional, technology and market-activity-based fees). As a reminder to regulated entities, this temporary relief expired on Friday, July 31, 2020.
See the press release on temporary fee waivers.
July 27, 2020: Dealer Disclosure Obligations Under MSRB Rule G-15
Dealers are reminded that under MSRB Rule G-15 written confirmations to customers, which are required to be sent at or before the completion of a transaction, should include, among other things, information related to the transaction and both descriptive and identifying information about the security. For example, if a security has additional credit backing, such as bond insurance, the confirmation should identify that there are multiple obligors.
July 20, 2020: SEC, MRSB, FINRA Address Municipal Advisor Compliance Matters
Do you have questions for the regulators on municipal advisor compliance matters?
The Securities and Exchange Commission, Municipal Securities Rulemaking Board and Financial Industry Regulatory Authority are holding a virtual Compliance Outreach Program for Municipal Advisors.
The webcast program will be held Thursday, August 13, 2020, from 1 p.m. to 3 p.m. ET.
Participants are encouraged to submit questions in advance of the event by emailing MSRBEvents@msrb.org.
Register for the webcast to get answers.
July 13, 2020: Dealer obligations for offerings with the CPFF or MLF
Dealers may be wondering if their transactions with the Commercial Paper Funding Facility (CPFF) or the Municipal Liquidity Facility (MLF) would trigger submission of new issue information to the MSRB. The answer is yes. Under Rule G-32, dealers should fulfill their applicable regulatory obligations, including the timely and accurate submission of information relating to the offering by completing Form G-32.
See Frequently Asked Questions Related to COVID-19 Pandemic Regulatory Relief.
July 6, 2020: Learn more about the SEC’s Temporary Conditional Exemptive Order
Questions about the Securities and Exchange Commission’s (SEC’s) Temporary Conditional Exemptive Order for certain municipal advisor activities?
Tune in for a virtual discussion hosted by the SEC on Tuesday, July 7 from 2 p.m. to 3 p.m. ET at www.sec.gov.
Staff from the SEC’s Division of Trading and Markets and Office of Municipal Securities will discuss the requirements and conditions of the order. A representative of the Municipal Securities Rulemaking Board (MSRB) will join to discuss MSRB rules relevant to the order. The SEC and MSRB staff will answer questions from the public regarding the order submitted prior to the event to MAWebinar@sec.gov.
Please register for the virtual event here.
June 29, 2020: Application of Rule G-23 to SEC’s Emergency Temporary Conditional Exemptive Order
The MSRB updated its frequently asked questions (FAQs) on COVID-19 pandemic-related regulatory relief and guidance. A new FAQ has been added that addresses the application of MSRB Rule G-23 to the Securities and Exchange Commission’s Emergency Temporary Conditional Exemptive Order concerning direct placements of municipal securities by registered municipal advisors. This resource should be read in conjunction with the applicable MSRB rules and interpretations.
Read the updated FAQs.
See our dedicated COVID-19 information page.
June 22, 2020: Documenting New or Modified Procedures
Regulated entities are reminded that any new or modified policies and procedures resulting from reliance on the temporary regulatory relief provided by the MSRB in Notices 2020-09 and 2020-11 from complying with existing obligations should be documented. In accordance with MSRB Rules G-8 and G-9, including, as applicable, Rules 17a-3, 17a-4 and 15Ba1-8 of the Securities Exchange Act of 1934, dealers and municipal advisors are required to make and preserve certain books and records.
Read the MSRB's Regulatory Relief FAQs document.
See our dedicated COVID-19 information page.
June 15, 2020: Read our FAQs on COVID-19-Related Regulatory Relief
In light of the disruptions to normal business operations as a result of COVID-19, the MSRB provided temporary regulatory relief to market participants by extending certain MSRB compliance and testing deadlines.
To help regulated entities understand the full scope of this compliance relief, the MSRB has now provided answers to frequently asked questions (FAQs). This resource should be read in conjunction with the applicable MSRB rules and interpretations.
Read the FAQs.
See our dedicated COVID-19 information page.
June 8, 2020: Share These Resources for Municipal Bond Investors
Investors who hold municipal securities may not be aware of the resources available to assist them in understanding how the current coronavirus disease (COVID-19) pandemic may affect their holdings. In order to highlight available MSRB resources and provide information on where to find COVID-19-related disclosures from issuers, the MSRB published an investor protection informational notice.
Read the notice.
View the MSRB's dedicated COVID-19 information page.
June 1, 2020: MLF Transaction Fee Waiver
In order to help assist the industry during the COVID-19 crisis, the MSRB is providing a temporary waiver of underwriting, transaction and technology assessments under its Rule A-13 for brokers, dealers and municipal securities dealers with respect to those transactions with the Federal Reserve’s Municipal Liquidity Facility (MLF). The waiver is temporary and only applicable during the duration of time the MLF is purchasing municipal securities, which is currently scheduled to cease on December 31, 2020.
Read the notice.
Access additional information on the MSRB’s COVID-19 response,
including data and regulatory relief efforts, on its dedicated
information page.
May 18, 2020: Enhanced Usability of Weekly Disclosure Summary Report
Last week, the MSRB enhanced the format of its weekly report aggregating disclosures submitted to the Electronic Municipal Market Access (EMMA®) website that reference COVID-19. The new format allows for more seamless searchability, permitting users to sort by category, issuer name, state and posted date. Follow the below link tomorrow for an updated report covering disclosures through the week ending May 17, 2020.
View the report.
View the MSRB's dedicated COVID-19 information page.
May 11, 2020: Review Your Trades
Under MSRB Rule G-14, on reports of sales or purchases, dealers must submit transaction data that conforms to the formats specified for the RTRS Portal used for trade submissions and dealers have an obligation to report this information promptly, accurately and completely.
A dealer is obligated to promptly review and address any problem or potential problem with submitted trade data that is reported to the dealer through the Message Portal, through the RTRS Web Portal or via electronic mail.
May 4, 2020: Check out the Spring Compliance Corner
Did you miss the Spring edition of the MSRB's Compliance Corner? The most recent compliance-dedicated newsletter covers the MSRB's COVID-19 response, compliance FAQs, enforcement insight for a MSRB Rule G-23 violation and more. Read it here. Previous editions are available on MSRB.org.
Make sure you are signed up to receive the next edition of Compliance Corner. Sign up here.
April 27, 2020: Don’t Forget Your Time of Trade Disclosures!
Does your firm have a process for calculating market discount to see if the De Minimis Rule applies for a customer’s trade?
Bonds with a de minimis amount of market discount are subject to more favorable tax treatment than bonds with a non-de minimis amount of market discount. Under MSRB Rule G-47, which requires brokers, dealers and municipal securities dealers to disclose to their customers all material information known about the transaction, this discount may be considered to be material.
Read the IRS Investment Income and Expenses publication for additional information.
April 20, 2020: Working From Home? Try MuniEdPro®
Looking for ways to stay productive while staying home? MuniEdPro® offers easy-to-access, free remote education for muni bond professionals. Complete your compliance training with timely content, direct from the regulators themselves. You now have a turnkey solution for training that you can access from your new home office.
Visit MSRB.org for more information on MuniEdPro® or start exploring a class today.
April 13, 2020: Review the MSRB's Temporary Compliance Relief
In light of the disruptions to normal business operations as a result of COVID-19, the MSRB announced regulatory relief to provide for an extension of time to implement certain amended rules and interpretive guidance, and additional time to complete certain professional qualification and supervisory requirements. MSRB-regulated firms will now have additional time to:
- Prepare to operationalize the submission of additional data related to primary offerings of municipal securities under amendments to MSRB Rule G-32;
- Prepare to operationalize compliance with amended and restated guidance regarding the fair dealing obligations underwriters owe to issuers of municipal securities under MSRB Rule G-17;
- Take and pass certain qualification exams and continuing education modules required by MSRB Rule G-3;
- Conduct the annual needs analysis and the delivery of continuing education content pursuant to MSRB Rule G-3;
- Conduct the annual compliance meeting and branch inspections pursuant to MSRB Rule G-27;
- Provide the annual report related to the dealer’s review of the firm’s supervisory controls under MSRB Rule G-27 ; and
- Provide the annual certification related to the municipal advisor firm’s compliance policies and procedures under MSRB Rule G-44.
Read more about the temporary regulatory relief.
April 6, 2020: Tracking COVID-19 Disclosures
The MSRB is now publishing a weekly summary identifying disclosures submitted to the EMMA® website by issuers of municipal securities that reference COVID-19. To compile the summary, the MSRB searched the approximately 40,000 disclosures the EMMA system received from January 2020 to March 2020 and identified those that referenced COVID-19 or related keywords.
View the first COVID-19-related disclosure summary (January 2020 -
March 2020).
View the MSRB’s dedicated webpage for COVID-19-related information and
market analyses.
March 30, 2020: New Daily Trade Activity Analysis
In order to assist market participants, policymakers and the general public with understanding the impact of COVID-19 on the liquidity of the municipal securities market, the MSRB is now publishing a daily trade activity report.
The report compares daily purchases and sales of fixed, variable and zero coupon bonds to historical averages from 2019 and early 2020.
View the MSRB’s analysis, which will be updated daily, here.
View the MSRB’s dedicated webpage for COVID-19-related information and
market analyses.
March 23, 2020: One Stop for MSRB Coronavirus Updates
The MSRB is closely monitoring the impact of the coronavirus disease (COVID-19) on municipal market participants, including municipal securities dealers and municipal advisors. Please reach out to us at compliance@msrb.org with any compliance questions or suggestions for how we can help regulated entities.
Stay up-to-date on MSRB information, including notices and market analysis, with a new dedicated COVID-19 information page on MSRB.org.
March 16, 2020: Supervisory Requirements in Light of Coronavirus
In light of the recent public health concerns due to the coronavirus (COVID-19) outbreak, the Municipal Securities Rulemaking Board (MSRB) recognizes that there may be operational challenges and business disruption for regulated entities. To address these concerns, the MSRB issued a reminder to regulated entities regarding the supervision of municipal securities and municipal advisory activities and that of their associated persons. Read the notice.
Broker-dealers should also read FINRA Regulatory Notice 20-08, which notes that FINRA is “temporarily suspending the requirement to maintain updated Form U4 information regarding office of employment address for registered persons who temporarily relocate due to COVID-19. In addition, member firms are not required to submit branch office applications on Form BR for any newly opened temporary office locations or space-sharing arrangements established as a result of recent events.”
March 9, 2020: Understanding How Continuing Disclosures Appear on EMMA®
Join MSRB staff on March 19, 2020, for a free webinar demonstrating upcoming enhancements to the Electronic Municipal Market Access (EMMA®) website, including:
- How submitters modify a published disclosure to replace files, correct categories and revise descriptive information that appears on the EMMA website;
- New features to display the history of modifications to a disclosure submission; and
- Upcoming enhancements to improve the transparency of the timing of issuers' annual and audited financial disclosures.
March 2, 2020: Think Before You Click!
Become cyber aware of suspicious emails. Phishing emails with malicious attachments are designed to look like legitimate emails. Clicking a link or opening an attachment from a phishing email is one of the leading root causes of data breaches. Recognizing that a cyber attack may have consequences that extend beyond the compromised firm, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations noted that information security will continue to be a priority in each of its examination programs.
Read the SEC’s 2020 Examination Priorities.
Read the SEC's Cybersecurity and Resiliency Observations Report.
February 24, 2020: LIBOR Transition
The Municipal Securities Rulemaking Board (MSRB) has published information regarding the transition from the LIBOR reference rate to encourage regulated entities to review their activities related to LIBOR transactions. The information is intended to highlight existing MSRB rules that promote the protection of municipal entities by ensuring they are apprised of the risks associated with the LIBOR reference rate when entering into new LIBOR-based transactions. Such information is of particular importance given that the financial authority responsible for the publication of LIBOR has stated that it cannot guarantee that the LIBOR reference rate will be published beyond 2021.
See MSRB Rule G-17, on fair dealing, and MSRB Rule G-42, on duties of non-solicitor municipal advisors.
February 10, 2020: Mark Your Calendars
Simplify your tracking of key compliance dates with the Municipal Securities Rulemaking Board's (MSRB) online Compliance Calendar. This compliance resource for municipal securities dealers and municipal advisors highlights upcoming deadlines, rule effective dates and events.
Have a suggestion for the compliance calendar? Contact the MSRB at compliance@msrb.org.
February 3, 2020: Best Execution with Limited Pricing Information
The absence or limitation of accessible quotations or pricing information is not uncommon for many municipal securities, but it does not relieve a dealer of its best-execution obligations. Supplementary Material .06 to Rule G-18 specifically requires dealers to have written policies and procedures in place that address how the dealer will make its best-execution determinations with respect to securities with limited quotations or pricing information, and address when those policies and procedures are triggered by establishing what it means to have limited quotations or pricing information. See Rule G-18 Interpretive Guidance.
January 27, 2020: Municipal Advisors – Review SEC Form MA-I
Each municipal advisory firm must complete and file U.S. Securities and Exchange Commission (SEC) Form MA-I with respect to each natural person associated with the firm and engaged in municipal advisory activities on the firm’s behalf. Firms must promptly amend information contained in a Form MA-I whenever information regarding the associated person becomes inaccurate, including promptly amending such forms to indicate when the associated person is no longer associated with municipal advisors.
The MSRB recommends firms review the accuracy of their Forms MA-I on file with the SEC. Professional fees assessed by the MSRB pursuant to MSRB Rule A-11 are calculated based on the number of associated persons qualified as a municipal advisor representative and for whom the municipal advisor firm maintains an active Form MA-I with SEC as of January 31 each year. See MSRB Rule A-11, on assessments for municipal advisor professionals.
January 13, 2020: Primary Offering Amendments Effective Today
Amendments to primary offering rules, including MSRB Rule G-11, on primary offering practices, and MSRB Rule G-32, on disclosures in connection with primary offerings, are effective today, January 13, 2020. Read the notice.
Note that the compliance date for amendments to Form G-32 is November 30, 2020. Read the notice.
The MSRB also recently published a notice reminding dealers that electronic media may be used to satisfy their delivery obligations under MSRB Rule G-11 for communications among dealers and between dealers and issuers. Read the notice.
January 6, 2020: Remember to Affirm or Update MSRB Form A-12
MSRB-registered firms are required to update MSRB Form A-12 within 30 days if any information on this registration form becomes inaccurate. During the Annual Affirmation Period, which commenced on January 1, firms must review their information on Form A-12 and either affirm that the information on the form remains accurate or make any necessary updates by January 27, 2020. Read more about the affirmation process.
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