SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on Supervision of Municipal Advisory Activities (Draft Rule G-44), Books and Records (Draft Rule G-8), and Preservation of Records (Draft Rule G-9).

SIFMA supports the MSRB’s efforts to ensure that municipal advisors are properly supervised and that all municipal advisors adopt a supervisory structure for municipal activities not already subject to supervision under Rule G-27. As discussed in SIFMA’s comment letters submitted previously to the MSRB in response to other proposed MSRB rule changes, since the Securities and Exchange Commission (SEC) has not yet adopted final rules that would define the scope of activities that trigger municipal advisor registration, and therefore the universe of potential registrants, the Proposal to establish a supervisory system for such activity is premature and may be an inefficient use of resources. Accordingly, SIFMA requests an opportunity to provide further comments once the SEC has completed its rulemaking defining the scope of activities subject to municipal advisor registration – and supervision. Once the SEC has completed its rulemaking defining the scope of personnel and activities subject to municipal advisor registration, we would expect the MSRB to propose a supervisory regime for non-dealer municipal advisors of similar robustness as the requirements of G-27 which covers dealer advisors.

SIFMA states the MSRB should delay its rulemaking until the SEC determines the definition of “municipal advisor.”