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
Municipal Finance Professional: Supervisor
Municipal finance professional: supervisor. This is in response to your inquiry seeking guidance regarding the possible classification as a municipal finance professional under rule G-37 of a Taxable Department Head at your firm. You stated that the Taxable Department Head is the direct supervisor of a Branch Manager and this Branch Manager manages a sales representative who has solicited municipal securities business from an issuer. You state that it is clear that the Branch Manager and the sales representative are both municipal finance professionals. However, you further state that the Taxable Department Head has delegated all Public Finance/Municipal oversight responsibilities to the Public Finance Department Head for the Taxable Department Head's personnel. You ask whether, under these circumstances, the Taxable Department Head would be considered a municipal finance professional under rule G-37 as a result of his or her supervisory position.
The term "municipal finance professional" is defined in rule G-37(g)(iv). Clauses (C) and (D) of the definition set forth the basis for considering an associated person of a dealer to be a municipal finance professional as a result of his or her supervisory position. Clause (C) includes any associated person who is both (i) either a municipal securities principal or municipal securities sales principal and (ii) a supervisor of any associated person either primarily engaged in municipal securities representative activities or who solicits municipal securities business (referred to herein as a "primary municipal securities supervisor"). Clause (D) includes any associated person who is a supervisor of a primary municipal securities supervisor up through and including (in the case of a non-bank dealer) the Chief Executive Officer or similarly situation official (referred to herein as a "secondary municipal securities supervisor").
Unlike in the case of a primary municipal securities supervisor, a secondary municipal securities supervisor is not required to be a municipal securities principal or municipal securities sales principal. The status of a secondary municipal securities supervisor as a municipal finance professional is not conditioned on the areas in which such supervisor has responsibility over a primary municipal securities supervisor, so long as such secondary municipal securities supervisor retains some degree of supervisory responsibility (whether or not relating to municipal securities activities) over the primary municipal securities supervisor. MSRB interpretation of November 23, 1999.