Select regulatory documents by category:
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated April 10, 2012
2. Full Life Financial LLC: Letter from Keith Newcomb, Portfolio Manager, dated April 14, 2012
3. Government Finance Officers Association: Letter from Susan Gaffney, Director, Federal Liaison Center, dated April 6, 2012
4. Kious and Co.: E-mail from Michael Kious dated March 13, 2012
5. M. E. Allison & Co., Inc.: Letter from Christopher R. Allison, Chief Financial Officer, dated March 13, 2012
6. McGuirk, Hugh: E-mail dated March 14, 2012
7. National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated April 9, 2012
8. Oppenheimer & Co. Inc.: Letter from Allison F. Fleitas II, Managing Director, Municipal Capital Markets Group
9. UMB Bank, N.A.: E-mail from Kristin Koziol dated March 30, 2012
1. Alamo Capital: E-mail from Bill Mullally dated March 9, 2012
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated April 13, 2012
3. CFA Institute: Letter from Kurt N. Schacht, Managing Director, Standards and Financial Market Integrity, and James C. Allen, Head, Capital Markets Policy, dated April 13, 2012
4. Edward D. Jones & Co., L.P.: Letter from David E. Fischer-Lodike, Capital Markets and Operations Compliance, dated April 13, 2012
5. Full Life Financial LLC: Letter from Keith Newcomb, Portfolio Manager, dated April 13, 2012
6. Government Finance Officers Association: Letter from Susan Gaffney, Director, Federal Liaison Center, dated April 13, 2012
7. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel-Securities Regulation, dated April 13, 2012
8. Li, Richard: Letter dated March 7, 2012
9. Melton, Chris: E-mail dated April 13, 2012
10. National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated April 13, 2012
11. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated April 13, 2012
12. Thornburg Investment Management: Letter from Josh Gonze, Chris Ryon, and Chris Ihlefeld, Co-Portfolio Managers, dated March 12, 2012
13. Vanguard: Letter from Christopher Alwine, Head of Municipal Bond Group, dated April 13, 2012
14. Wells Fargo Advisors: Letter from Ronald C. Long, Director of Regulatory Affairs, dated April 13, 2012
1. Broadridge Financial Solutions, Inc.: Letter from Charles V. Callan, Chief Regulatory Officer, dated April 2, 2012
2. College Savings Foundation: Letter from Roger Michaud, Chairman, dated April 2, 2012
3. College Savings Plans Network: Letter from Michael L. Fitzgerald, Chair, College Savings Plans Network, & State Treasurer of Iowa, dated April 2, 2012
4. Commonwealth Financial Network: Letter from Brendan Daly, Legal and Compliance Counsel, dated March 30, 2012
5. Consumer Federation of America: Letter from Barbara Roper, Director of Investor Protection, dated May 7, 2012
6. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated April 2, 2012
7. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated April 2, 2012
8. Sutherland Asbill & Brennan LLP: Letter from Michael Koffler dated April 2, 2012
9. T. Rowe Price Associates, Inc.: Letter from David Oestreicher, Chief Legal Counsel, and Regina M. Watson, Senior Associate Counsel, dated April 2, 2012
10. Utah Educational Savings Plan: Letter from Lynne N. Ward, Executive Director, dated April 2, 2012
11. Virginia College Savings Plan: Letter from Mary G. Morris, Chief Executive Officer, dated April 2, 2012
1. BondView: Letter from Robert Kane, CEO, dated March 5, 2012
2. Government Finance Officers Association: Letter from Susan Gaffney, Director, Federal Liaison Center, dated March 9, 2012
3. Haynsworth Sinkler Boyd, P.A.: Letter from Kathleen Crum McKinney and Theodore B. DuBose, dated March 5, 2012
4. Ice Miller LLP: Letter from Philip C. Genetos dated March 6, 2012
5. Indiana Housing & Community Development Authority: Letter from Blake A. Blanch, Chief Financial Officer
6. Indianapolis Airport Authority: Letter from Joseph R. Heerens, Chief Legal Officer, dated March 6, 2012
7. Los Angeles County Metropolitan Transportation Authority: Letter from Michael J. Smith, Assistant Treasurer
8. National Association of Bond Lawyers: Letter from Kristin H.R. Franceschi, President, dated March 8, 2012
9. National Federation of Municipal Analysts: Letter from Lisa Good, Executive Director, dated March 26, 2012
10. Squire Sanders LLP: Letter dated March 6, 2012
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.
