The MSRB proposed extending the deadline for muni brokers, dealers, municipal securities dealers and municipal advisors to annually affirm the information on Form A-12, the MSRB’s consolidated electronic registration form (see MSRB Rule A-12.)
The proposal would extend the deadline to affirm Form A-12 information from 17 business days after January 1 to January 31. The proposal would also remove the requirement for firms to provide a separate notice to regulators in Form A-12 prior to engaging in municipal securities or municipal advisory activities. Instead, each firm will be required to provide (i) its principal regulator (which will be a banking agency for banks that are registered as muni dealers) and (ii) contact information for the firm’s contact at that regulator. The primary regulatory contact at a municipal advisor firm would also be required to register as a municipal advisor principal after passing the Series 54 Municipal Advisor Principal Qualification Examination.
The MSRB filed the rule change for immediate effectiveness, and it will go into effect beginning on January 1, 2023.
December 14 2022
Fried Frank Harris Shriver & Jacobson LLP