Found inside – Page 67An independent body would be created to receive , investigate , and resolve material complaints from banks in a timely and confidential ... Serving Local Governments : Community Bank Exemption from Municipal Advisor Registration . In addition, the staff reminds municipal advisors that, pursuant to Exchange Act Section 15B(c)(3), the Commission, by order, shall cancel the registration of a municipal advisor if it finds that the municipal advisor is no longer in existence or has ceased to do business as a municipal advisor. In this instance, in the staff’s view, the broker-dealer would not be providing the municipal entity with post-issuance advice on an outstanding issuance of municipal securities. Minnesota Housing Independent Registered Municipal Advisor Notice. In these circumstances, do such proceeds of pension obligation bonds cease to be considered “proceeds of municipal securities” under the Final Rules upon their contribution to the public pension plan? An independent registered municipal advisor is providing advice with respect to the same aspects of the municipal financial product or issuance of municipal securities. A person who meets the definition of “municipal advisor” and does not qualify for an exclusion or exemption on or after October 1, 2014 is not required to register with the Commission using Form MA-T under the Temporary Registration Rule (and instead is required to register using the final forms as discussed in the Answer to Question 9.2 below). The SEC's final municipal advisor registration and recordkeeping Rules 15Ba1-1 through 15Ba1-8 and 15Bc4-1 were effective July 1, 2014. Answer: Yes. [23] [May 19, 2014]. On December 31, 2015, the staff received a letter from Robert A. Fippinger, Chief Legal Officer of the MSRB (the “MSRB ABLE Accounts Letter”), requesting guidance from the staff as to whether interests in an ABLE account established by a State, or an agency or instrumentality thereof pursuant to an ABLE Act program (“ABLE Program”) are “municipal securities,” as defined in Section 3(a)(29) of the Exchange Act. Found inside – Page 239Effective October 1, 2010, the Dodd–Frank Act imposed for the first time a requirement for municipal advisors to register with the SEC. The SEC adopted a broad definition of municipal advisor on a preliminary basis: □ A person (who is ... MSRB Holds Quarterly Board Meeting and Elects New Officers Friday, July 23, 2021. Individuals purchasing trust interests do not have a right to control the investment of trust assets, although they may have the ability to choose from among several types of investment products in which to invest their ABLE account funds. SUBJECT: Notice to Municipal Market Participants . Answer: In regard to the underwriter exclusion to the municipal advisor definition, the Commission explained in the Adopting Release that, in order for a person to be “serving as an underwriter” with respect to the issuance of municipal securities within the meaning of the underwriter exclusion, there must be a relationship to a particular transaction, and that, for example, a contractual “engagement” by a municipal entity of a broker-dealer to serve as underwriter on a specific planned transaction for the issuance of municipal securities would constitute the requisite engagement on a particular issuance of municipal securities. [72] See Adopting Release, 78 FR at 67584-67585. [January 10, 2014]. Keller Independent School District ("KISD") has retained an independent registered municipal advisor. Effect of Overall Course of Conduct on Advice Analysis. Broker, dealer, or municipal securities dealer serving as an underwriter of a particular issuance of municipal securities. For example, if a broker-dealer provided debt structuring options that were tailored to address the specific needs, objectives, or circumstances of a municipal issuer, such as tailored sizing, maturity, or security structures to address particular needs, circumstances, or objectives of the municipal issuer within the issuer’s overall debt structure, the staff believes that presenting these particularized debt structuring options likely would suggest a preferred financing approach that likely would imply a recommendation. Answer: Exchange Act Section 15B(e)(4)(C) excludes from the municipal advisor definition attorneys offering legal advice or providing services that are of a traditional legal nature with respect to the issuance of municipal securities or municipal financial products. Answer: Yes. Absent an available exclusion or exemption, the staff believes that an engineer providing such advice would fall within the scope of the municipal advisor definition under the Final Rules and would be required to register with the Commission as a municipal advisor. Answer: The Final Rules were effective on January 13, 2014; however, on January 13, 2014, the Commission temporarily stayed the Final Rules until July 1, 2014 to provide market participants with a limited amount of additional time to analyze, implement, and comply with the Final Rules. The MSRB has stated that, after September 12, 2017, “only an associated person of a municipal advisor who is qualified by passing the Series 50 exam can engage in municipal advisory activities on behalf of a municipal advisor.”[68] Specifically, MSRB Rule G-3(d) states, among other things, that every “municipal advisor representative” — any natural person associated with a municipal advisor who engages in municipal advisory activities on a municipal advisor’s behalf[69] — shall take and pass the Series 50 Exam prior to being qualified as a municipal advisor representative. Our clients include cities, public school districts, community college districts, water authorities, special districts, and various other . Answer: Yes, in the staff’s view, under the circumstances described in Question 11.2, such proceeds of pension obligation bonds lose their character as proceeds of municipal securities under the Final Rules upon their contribution to the public pension plan. Found inside – Page 176Financial Advisors and Investment Brokers and Other Municipal Market Participants . ... It should be noted that many financial advisory firms are registered as broker - dealers or municipal securities dealers and are , therefore ... MSRB Announces New Board Members for Fiscal Year 2022 Wednesday, August 4, 2021. PFM is a "municipal advisor" as defined under the Rule in connection with those proposals and recommendations. Commodity trading advisor registered under the Commodity Exchange Act or persons associated with a registered commodity trading advisor. . The staff believes an engineer could rely on the engineering exclusion when providing advice on the engineering aspects of a new project that will be financed, in whole or in part, by an issuance of municipal securities; provided that such advice does not include advice with respect to structure, timing, terms, or other similar matters concerning such issuance of municipal securities. It is also the staff’s view that a market participant could provide the following services without engaging in municipal advisory activity: (a) remind a municipal entity generally of its continuing disclosure filing obligations; (b) provide a municipal entity with assistance submitting continuing disclosure filings to the MSRB’s Electronic Municipal Market Access (“EMMA”) system; and (c) notify a municipal entity whether, and to what extent, any of its continuing disclosure filings actually appeared on EMMA. The staff further believes that, while the presentation of information with the disclosures and disclaimers described above are factors that suggest that a person may not be making a recommendation that would constitute advice under the Final Rules, such disclosures and disclaimers are not controlling and must be considered in the context of a person’s overall course of conduct, taking into account all of the relevant facts and circumstances. KISD is represented by and will rely on its municipal advisor, Hilltop Securities to provide advice on proposals from financial services firms concerning the issuance of . On September 20, 2013, the Securities and Exchange Commission adopted new rules and forms to establish a registration regime for municipal advisors.  These new rules and forms implement Section 975 of the Dodd-Frank Act, which amended Section 15B of the Securities Exchange Act of 1934.  Section 15B of the Exchange Act requires municipal advisors to register with the SEC. Official and employee of a municipal entity or obligated person. [37] See Adopting Release, 78 FR at 67495 (describing the Commission’s belief that a determination of whether or not a person has a reasonable basis to rely on a written representation requires reasonable diligence based on all the facts and circumstances, including review of the written representation and other relevant information reasonably available to the person). That is, persons providing advice with respect to the investment of monies in ABLE accounts issued pursuant to ABLE Programs would not be required to register as municipal advisors based on the definition of “proceeds of a municipal security” to the extent their municipal advisory activities are limited to such advice. Thus, for example, a market participant reasonably could know that an existing account or existing investment may contain proceeds of municipal securities if the account holder is a municipal entity or the account name suggests a connection to municipal securities (e.g., the name of the account refers to municipal securities, municipal bonds, or fund names commonly known to be related to municipal securities, such as a debt service reserve fund account). The municipal entity, obligated person, or other financing transaction participant, in turn, could use such information to structure the timing and terms of debt service payments on the related issuance of municipal securities and, based on such debt service structure and projected net revenues, provide a projected debt service coverage table for inclusion in the offering document for the issuance of municipal securities. Question 11.3: Application of Proceeds Exception for Section 529 College Savings Plans to ABLE Programs: In the Final Rules[43], monies derived from a municipal security issued by an education trust established by a State under Section 529(b) of the Internal Revenue Code[44] (a “529 Savings Plan”) are excluded from the definition of “proceeds of municipal securities.” In the staff’s view, are monies derived from a municipal security issued by a State, or an agency or instrumentality thereof pursuant to the Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014[45] (the “ABLE Act”) also excluded from such definition? KISD is represented by and will rely on its municipal advisor, Hilltop Securities to provide advice on proposals from financial services firms concerning the issuance of . [September 20, 2017]. [1] Responses to these FAQs were prepared by and represent the views of the staff. The Municipal Advisor Firms tab displays municipal advisor firms registered with the MSRB with at least one individual associated with the firm who has passed the MSRB's Municipal Advisor Representative Qualification Examination (Series 50). Fiscal Strategies Group Inc. (FSG) is an independent financial advisory firm that provides financial advisory services to state and local governmental clients. Answer: The Answer to Question 1.1 of these FAQs regarding the general information exclusion from advice generally applies and is relevant to this analysis. For example, if a municipal issuer had outstanding fixed rate municipal securities involving a debt structure with level annual payment debt service payments and a 30-year final maturity date, the staff believes that if business promotional materials included mathematical calculations showing hypothetical potential interest cost savings if the municipal issuer were to issue refunding bonds to refinance those outstanding municipal securities using a different debt structure that had features tailored or particularized for the municipal issuer that went beyond the existing structure of the outstanding bonds to be refunded (such as a structure involving nonlevel annual debt service payments, non-interest paying capital appreciation bonds, or any extension of the final maturity date beyond that of the outstanding bonds to be refunded), those business promotional materials likely would imply a recommendation. Question 2.1: Parameters and Formality of RFP/RFQ Process: Describe a request for proposals (“RFP”) or request for qualifications (“RFQ”) process that is consistent with the exemption to the municipal advisor definition for any person who provides a written or oral response to an RFP or RFQ? In a letter responding to the MSRB ABLE Accounts Letter, the staff expressed the belief that at least some interests in ABLE accounts as described in the MSRB ABLE Accounts Letter may be “municipal securities” as defined in Section 3(a)(29) of the Exchange Act depending on the facts and circumstances, including without limitation, the extent to which an ABLE account offered through an ABLE Program is a direct obligation of, or obligation guaranteed as to principal or interest by, a state or any agency or instrumentality thereof.[48]. of the Instructions for the Form MA Series, Adopting Release, 78 FR at 67641-67642. On January 13, 2014, the Commission temporarily stayed the final rules for municipal advisor registration until July 1, 2014. [23] See generally 15 U.S.C. Independent Registered Municipal Advisor Disclosure Certificate . [46] The staff, based on the MSRB ABLE Accounts Letter and other communications with the MSRB staff, understands that ABLE Programs bear a number of similarities to 529 Savings Plans. How you know. Found inside – Page 39The Dodd - Frank Act has fundamentally altered the relationship of municipal advisors and municipal entities . ... 9 See , e.g. , MSRB Comment Letter Re : SEC Proposed Rules on Registration of Municipal Advisors , File No. It is the staff’s view that the same “associated” person analysis described above also should apply to the converse situation in which a current employee of a transaction participant firm formerly was employed, within the past two years, by a registered municipal advisor firm. [58] Exchange Act Rule 15Ba1-1(d)(2)(iv). If there were a remarketing of the issue of the municipal securities that constituted a primary offering, the remarketing agent should reevaluate its activities to determine if an exclusion from registration (such as the underwriter exclusion) applies. The Answer to Question 10.1 of these FAQs generally applies and is relevant to the analysis of the broker-dealer’s advice on the refunding issuance of municipal securities. By contrast, however, in the staff’s further view, if a municipal entity segregates proceeds of pension obligation bonds and continues to account for them separately as proceeds of the pension obligation bonds or retains control over the ability to use such funds for any purpose other than the exclusive benefit of pension beneficiaries, such proceeds continue to constitute proceeds of municipal securities under the Final Rules until used ultimately to pay pension benefits to pension fund beneficiaries or to carry out other authorized purposes of the pension obligation bonds. The firm provides bond structuring advice, credit rating strategy and pricing comfort at the time of bond sale. The staff does not believe, however, that, for purposes of this exemption, “rely on” means that the municipal entity or obligated person must follow the advice of the independent registered municipal advisor. The staff believes, however, that an engineer providing advice on how to structure the related issuance of municipal securities, including the length of any capitalized interest period and the amount of capitalized interest to be financed, would constitute municipal advisory activities outside the scope of the engineering exclusion. With respect to investment advice provided on or after July 1, 2014 regarding investments of newly-arising proceeds received from municipal securities that are issued on or after that date, market participants should develop policies and procedures consistent with the Final Rules and the Commission’s guidance in the Adopting Release to determine whether or not the advice provided involves investments of proceeds of municipal securities. The Final Rules limit the scope of the attorney exclusion to such advice or services the attorney provides to the attorney’s client that is a municipal entity, obligated person, or other participant in the transaction. [January 10, 2014]. Can the independent municipal advisor exemption apply in circumstances involving a registered municipal advisor that serves in a general capacity? Exchange Act Rule 15Ba1-1(m) establishes an exception from the definition of proceeds of municipal securities, which provides that, solely for purposes of Rule 15Ba1-1(m), monies derived from a municipal security issued by an education trust established by a State under Section 529(b) of the Internal Revenue Code are not proceeds of municipal securities. If the municipal entity provides one written representation to all the transaction participants that it is represented by, and will rely on the advice of, its independent registered municipal advisor, would this written representation satisfy the requirement set forth in the second clause of the exemption (set forth in Rule 15Ba1-1(d)(3)(vi)(B) and described in the Answer to Question 3.1 above)? Question 6.1: Updating Omissions in an Offering Document: A broker-dealer served as underwriter for an issuance of municipal securities. To access EDGAR, municipal advisors need an access code. Overview. Such assistance would require the market participant to express an opinion that would be considered advice under the Final Rules. [72] [September 20, 2017]. Found inside – Page 73unlawful for any municipal advisor to provide advice to a municipality unless registered with the Commission . ... the ability of the Public Company Accounting Oversight Board to implement its new oversight authority over independent ... Absent an available exclusion or exemption, such as the exclusion for a registered broker-dealer serving as underwriter on a particular issuance of municipal securities after engagement in such capacity, a broker-dealer cannot provide advice on an issuance of municipal securities without registering with the Commission as a municipal advisor. The staff believes that the scope of this interpretation would be consistent with the scope of advice under clause (a) in the first paragraph of this Answer that is outside the registered investment adviser exclusion (i.e., advice concerning whether or how to issue municipal securities and advice concerning the structure, timing, and terms of an issuance of municipal securities and other similar matters). Since the independent registered municipal advisor is advising the municipal entity with respect to the same aspects of the issuance of municipal securities, it is the staff’s view that the municipal advisor will be able to subsequently meet or have discussions with the municipal entity and evaluate any advice provided by the broker-dealer and does not need to be present for every conversation. In the staff’s view, the broker-dealer’s action also would be promoting compliance with the anti-fraud provisions of the federal securities laws, which would help to ensure investors who purchase the municipal securities of this municipal entity in the secondary market received annual continuing disclosure filings and event notices in a timely manner. An official website of the State of Georgia. [13] See Answer to Question 5.1 herein discussing how a broker-dealer’s unilateral action to identify itself in writing as an underwriter and not as a financial advisor under MSRB Rule G-23 for purposes of that conflicts rule is insufficient to establish that the broker-dealer has been engaged to serve as underwriter on a particular issuance of municipal securities and thereby does not meet the underwriter exclusion. For example, in the staff’s view, absent the availability of another exemption,[30] a market participant could not assist a municipal entity with assessing whether an event is “material” under the federal securities laws and whether the municipal entity is required to file an event notice pursuant to a continuing disclosure agreement without falling within the scope of the municipal advisor definition. [42] The staff notes that, in general, municipal entities do not issue tax-exempt bonds to fund public pension plans because the Federal tax arbitrage investment restrictions under Section 148 of the Internal Revenue Code treat proceeds of such bonds as unspent and subject to arbitrage investment restrictions until used to carry out their governmental purpose to pay retirement benefits. In the staff’s view, however, if a bank provides advice to a municipal entity or obligated person regarding the structuring, timing, terms, and similar matters with respect to an issuance of municipal securities that extends beyond those municipal securities that the bank plans to purchase for its own account, such advice would constitute municipal advisory activity that is outside the scope of the bank exemption under the Final Rules. As noted in the Adopting Release, the Commission interprets the definition of municipal advisor to include a person who engages in the solicitation of an obligated person. Found inside – Page 29Better Oversight of Municipal Securities Industry : • Registers Municipal Advisors : Requires registration of municipal ... of independent members , to ensure that the public interest is better protected in the regulation of municipal ... Swap dealer registered under the Commodity Exchange Act or associated persons of the swap dealer. SGA is an SEC and MSRB registered municipal advisor, and is a member of the National Association of Municipal Advisors (NAMA). Found inside – Page 87Commodity futuros contracts investment advisor ... 27 Commodity spoclallet . ... 19 Municipal advisory council required to register ... 81 Municipal bond advisers ... 26 Independent firm pension consulting ... 32 Municipal bonds ... [73] See MSRB Rule G-2; MSRB Rule G-3(d). The proposing release can be found on the SEC’s website at http://www.sec.gov/rules/proposed/2010/34-63576.pdf. Question 12.2: Engineering Advice Regarding Loan Applications for State Revolving Funds: If an engineer assists a municipal entity or obligated person with completing a loan application for state revolving funds, would such assistance be considered municipal advisory activity under the Final Rules? Found insideIAs and municipal advisors registration Forms (Forms ADV and MA) are publicly available on the SEC's website. ... custodian's safeguards, such as having and an independent public artountant ronduct a surprise audit at least ance a year. The issuer must represent in writing to the underwriter that it has retained and will rely on a municipal advisor for advice (preferably through the use of a contract with the MA). Independent Registered Municipal Advisor (IRMA) Exemption Letter. On August 23, the FDA announced the full approval of the Pfizer-BioNTech vaccine for the prevention of COVID-19 disease in individuals age 16 and older. Independent Registered Municipal Advisor Disclosure Certificate January 1, 2021 To all financial services firms, including potential underwriters and placement agents: Colorado Springs Utilities recognizes that the U.S. Securities and Exchange Commission ("SEC") has issued rules Does the analysis change if the advice relates to an existing project that was financed, in whole or in part, by one or more outstanding issues of municipal securities? To all potential underwriters, placement agents and other market participants : THE COLORADO DEPARTMENT OF TRANSPORTATION ("CDOT"), THE COLORADO HIGH PERFORMANCE TRANSPORTATION ENTERPRISE ("HPTE") and THE COLORADO BRIDGE Answer: Pursuant to an express provision in the bank exemption in the Final Rules, a bank may provide advice to a municipal entity or obligated person with respect to “the purchase of a municipal security by the bank for its own account.”[56] In the Adopting Release, the Commission stated in relevant part that “banks providing municipal entities or obligated persons with the terms under which they would purchase securities for their own account are not engaging in municipal advisory activity.”[57] Accordingly, a bank may rely on the bank exemption in the Final Rules to give advice to a municipal entity regarding the structure, timing, and terms under which the bank would purchase securities for its own account. 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