Select regulatory documents by category:
Dealers, General Public, Investors, Issuers, Municipal Advisors
All Comments to Notice 2024-15
- ABLE Savings Plan Network: Letter from Bette Ann Mobley, Chair, dated April 10, 2025
- AKF Consulting Group: Letter from Andrea Feirstein, Managing Director, and Mark Chapleau, Senior Consultant, dated April 11, 2025
- Arizona State Treasurer’s Office: Letter from Kimberly Yee, Treasurer, dated April 10, 2025
- Ascensus: Letter from Christal Fenton, Associate General Counsel, dated April 10, 2025
- Bank of North Dakota: Email from James Barnhardt dated April 3, 2025
- College Savings Foundation: Letter from Chris McGee, Chair, dated April 9, 2025
- College Savings Plans Network: Letter from Mary G. Morris, Chair, dated April 2, 2025
- Commonwealth Savers Plan: Letter from Mary G. Morris, Chief Executive Officer, dated April 11, 2025
- First Public, LLC: Email from Bill Mastrodicasa dated April 11, 2025
- Government Finance Officers Association: Letter from Emily Brock, Director of Federal Liaison Center, dated June 3, 2025
- Illinois State Treasurer’s Office: Letter from Michael W. Frerichs, Treasurer, dated April 10, 2025; and Letter from Michael Frerichs, Treasurer, dated April 10, 2025
- Investment Company Institute: Letter from Tara Buckley, Deputy General Counsel, Financial Regulation, and Shannon Salinas, Associate General Counsel, Retirement Policy, dated April 11, 2025
- Massachusetts Educational Financing Authority: Letter from Thomas M. Graf, Executive Director, dated April 9, 2025
- my529: Letter from Richard K. Ellis, Executive Director, dated March 31, 2025
- Nebraska State Treasurer’s Office: Letter from Rachel Biar, Deputy State Treasurer for Savings Programs, dated April 2, 2025
- Pennsylvania Treasury Department: Letter from Stacy Garrity, Treasurer, dated April 2, 2025
- Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Gerald O’Hara, Vice President and Assistant General Counsel, dated April 11, 2025
- TIAA-CREF Tuition Financing, Inc: Letter from Christopher S. Lynch, President, dated April 10, 2025
- Vestwell: Letter from Aaron Schumm, Chief Executive Officer, dated April 11, 2025
Dealers, General Public, Municipal Advisors
All Comments to Notice 2024-14
- American Securities Association: Letter from Jessica R. Giroux, General Counsel and Head of Fixed Income Policy, dated January 28, 2025
- Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated January 28, 2025
- ICE Bonds Securities Corporation: Letter from Robert Laorno, General Counsel, dated January 21, 2025
- National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 28, 2025
- Public Resources Advisory Group, Inc.: Letter from Thomas F. Huestis, Senior Managing Director, dated January 27, 2025
- Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Gerald O’Hara, Vice President and Assistant General Counsel, dated January 28, 2025
Dealers, General Public, Investors, Issuers, Municipal Advisors
Dealers, General Public, Investors
Dealers, General Public, Investors
All Comments to Notice 2024-09
- Association of Registration Management, Inc.: Letter from Richard Izzo, President, dated August 5, 2024
- Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated August 5, 2024
- Frost Bank Capital Markets Division: Letter from Jeff Beckel, SEVP and Director of Capital Markets, dated July 30, 2024
- Frost Bank Capital Markets Division: Email from Trevor Cross dated July 30, 2024
- Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, Head of Municipal Securities, dated August 5, 2024
Dealers, General Public, Investors, Issuers
Bank Dealers, Dealers, General Public, Investors
Dealers, General Public, Investors, Issuers
Municipal Advisors
Dealers, Municipal Advisors
Dealers, Municipal Advisors
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.
