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
Reminder Notice on Fair Practice Duties to Issuers of Municipal Securities
The Municipal Securities Rulemaking Board (“MSRB”) has recently provided guidance regarding the fair practice and related obligations of brokers, dealers and municipal securities dealers (“dealers”) to investors.[1] Specifically, MSRB Rule G-17, on conduct of municipal securities activities, states that, in the conduct of its municipal securities business, each dealer shall deal fairly with all persons and shall not engage in any deceptive, dishonest, or unfair practice. The MSRB is publishing this notice to remind dealers that the fair practice requirements of Rule G-17 also apply to their municipal securities activities with issuers of municipal securities.
As noted above, the fair practice requirements of Rule G-17 apply to all municipal securities activities of dealers with issuers. In particular, even where other MSRB rules provide for specific disclosures or other actions by, or establish specific standards of behavior for, dealers with respect to or on behalf of issuers, such disclosures, actions or behavior must also comport with the fair practice principles of Rule G-17. The MSRB will continue to review practices with respect to dealer activities with issuers.
[1] See MSRB Notice 2009-42 (July 14, 2009).
[2] See Rule G-17 Interpretive Letter – Purchase of new issue from issuer, MSRB interpretation of December 1, 1997, reprinted in MSRB Rule Book.
[3] See MSRB Rule G-20 Interpretation — Dealer payments in connection with the municipal securities issuance process, MSRB interpretation of January 29, 2007, reprinted in MSRB Rule Book.
