Select regulatory documents by category:
Bank Dealers, Dealers, Municipal Advisors
All Comments to Notice 2019-13
1. Acacia Financial Group, Inc.: Letter from Kim M. Whelan, Co-President, and Noreen P. White, Co-President, dated August 19, 2019
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated August 23, 2019
3. Columbia Capital Management, LLC: Letter from Jeff White, Managing Member, dated August 19, 2019
4. Crews & Associates, Inc.: Letter from Don Winton, Chief Operating Officer, dated August 23, 2019
5. Ehlers: Letter from Phil Cosson, Ehlers Board Chairman
6. First Kentucky Securities Corp.: Email from Stan Kramer dated August 13, 2019
7. Government Finance Officers Association: Letter from Emily Swenson Brock, Director, Federal Liaison Center, dated August 19, 2019
8. KPM Financial, LLC: Letter from Jay Saunders, Director
9. Kutak Rock LLP: Letter from Joshua P. Meyer dated August 16, 2019
10. Lewis Young Robertson & Burningham, Inc.: Letter from Laura D. Lewis, Principal, dated August 7, 2019
11. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated August 19, 2019
12. Phoenix Advisors, LLC: Letter from David B. Thompson, CEO, dated August 14, 2019
13. Richard Li: Email dated January 29, 2020
14. Robert W. Doty: Letter dated August 19, 2019
15.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 August 19, 2019
16. Speer Financial, Inc.: Letter from Daniel Forbes, President, dated August 19, 2019
17. State of Florida, Division of Bond Finance: Letter from J. Ben Watkins III, Director, dated September 3, 2019
18. Zions Public Finance, Inc. and Zions Bank Public Finance: Letter from James Livingston, Executive Vice President, dated August 14, 2019
Municipal Advisors
All Comments to Notice 2019-08
1. Bernardi Securities, Inc.: Letter from Lou Lamberti, Sr. Vice President, dated May 24, 2019
2. Bloomberg L.P.: Letter from Peter Warms, Senior Manager, Entity and Identifier Services, dated May 28, 2019
3. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated May 28, 2019
4. Dixworks LLC: Letter from Dennis Dix, Jr., dated March 4, 2019
5. Lamont Financial Services Corporation: Letter from Robert A. Lamb, President, dated May 7, 2019
6. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated May 28, 2019
7. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated May 28, 2019
8. Municipal Solutions, Inc.: Letter from Jeffrey R. Smith, President, dated May 28, 2019
All Comments to Notice 2019-01
1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated March 5, 2019
2. Regional Brokers, Inc.: Letter from H. Deane Armstrong, CCO, and Joseph A. Hemphill, CEO, dated March 7, 2019
3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 6, 2019
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.
