exemption to municipal advisor rule

Independent Registered Municipal Advisor (IRMA) Exemption Notice This notice has been prepared and made available by the California Department of Transportation (Department) in response to the Securities and Exchange Commission's Rule 15Ba1‐1(d)(3)(vi)(B) (Municipal Advisor Rule) promulgated under the Securities Exchange Act of . Independent registered municipal advisor exemption to Rule 15B of the Securities and Exchange Commission regarding the Registration of Municipal Advisors (SEC Municipal Advisors Rule.) Found inside – Page 166The new rule approved by the SEC requires a municipal adviser to permanently register with the SEC if it provides advice on ... for the institution, are exempted—along with municipal employees—from the rule being applied to advisers. Independent Registered Municipal Advisor Exemption. Home ->> CDIAC ->> Muncipal Maket Regulatory Activity ->> The Municipal Advisor Rule. Section 15B of the Securities Exchange Act defines the term "municipal advisor" to mean a person that (i) provides advice to or on behalf of a municipal entity or obligated person with respect to municipal financial products or the issuance of municipal securities, including advice with respect to the structure, timing, terms, and other similar matters concerning such financial products or issues, or (ii) undertakes a solicitation of a municipal entity. Under the definition of municipal advisor, a solicitor must perform such services for “direct or indirect compensation” on behalf of an unaffiliated entity. A Municipal Advisor may wish to take advantage of the Rule by offering to provide a specified set of services, such as review of a certain number of proposals, for a regular, but relatively modest retainer, so that the Borrower can have the benefit of both the IRMA exception and the Municipal Advisor's review of proposals, and the Municipal . The same holds true for accountants involved in a municipal securities issuance, as long as they only provide audit or other accounting services. Generally, the SEC regulates investment adviser firms with more than $100 million in assets under management (and certain other investment adviser firms that meet other statutory criteria). Municipal Entity Represented by an Independent Municipal Advisor The regulation exempts from the rule any person providing advice if the municipal entity is otherwise represented by an independent registered Sarasota County has retained an independent registered municipal advisor. Municipal Entity Represented by an Independent Municipal Advisor The regulation exempts from the rule any person providing advice if the municipal entity is otherwise represented by an independent registered © 2021 California State Treasurer's Office, MA Rules and Their Effect on Public Investments, Municipal Advisor Rule, Forms and Resources, SEC Final Rule: Registration of Municipal Advisors (MAs), Registration of MAs: Frequently Asked Questions (FAQs), GFOA Primer: Municipal Advisor Rulemaking and Issuers. Found inside – Page 61Already we are seeing proposals -- such as those implementing the rules regarding interchange , municipal advisors , and swaps transactions — that fail that simple test . Some rules under Dodd - Frank , if done improperly ... A municipal advisor is a person or firm, other than an underwriter, who advises a "municipal entity" or "obligated person" on bond offerings. Found inside – Page 6099(4) The Commission, by rule or order, upon its own motion or upon application, may conditionally or unconditionally exempt any broker, dealer, municipal securities dealer, or municipal advisor, or class of brokers, dealers, municipal ... By publicly posting the written disclosure contained in the link below, the City of Portland, Oregon intends that market participants receive and use it for purposes of the independent registered municipal advisor exemption to Rule 158 of the Securities and Exchange Commission regarding . Banks that provide advice to municipalitiesor obligatedpersons,orprovideadvicewithrespecttomunicipalderivatives,maybesubjectto registration unless another exemption applies. Parties that typically participate in municipal financing as part of team may also be exempt from the definition of municipal advisor, as long as they do not start providing advice as defined under the Rule. Found inside – Page 17037 The SEC believes that municipal advisors and municipal securities dealers may be less likely to qualify as ... rules related to investment advisers exempt from registration with the SEC , including " exempt reporting advisers " ) . The rule seeks to eliminate that overlap with this key difference: Municipal advisors have an explicit fiduciary responsibility to solely their government clients. � In addition, the final rule created several new exemptions from registration that can be . H�t��n� ����SE8K˃������;�c�\�e��H�!R�������p��@߼#F����M^ L�(C�H%��Vw��#4��K��3[h[B?2�_`s|y��~{VzJa���YڲG�8��%ze�|6_߷☜�A�&��������3���gk@s�Vbp\��fA��X���y���4�5C�X>��+����G$�nO�,��:Ag]IA^�. Employees and officials of obligated persons are also exempt. 2424 Piedmont Rd. 0000013686 00000 n he MA Rule was enacted as part of the inancial reg­ ulatory reform initiated under the Dodd- The staff initially issued these FAQs on January 10 . xref Pay Lodger's Tax/Hospitality Fee (Occupancy Tax), Liquor Permits and Pawn Permits. Independent Registered Municipal Advisor Exemption. By publicly posting the following written disclosure, The Illinois State Toll Highway Authority (the "Authority") intends that market participants receive and use it for purposes of determining the availability 0000005746 00000 n SEC Municipal Advisor Rule . Exempt reporting advisers and state-registered advisers are not covered by this exemption. [4] The Final Release at pages 175-176; Rule 15Ba1-1(m)(1), which defines “proceeds of municipal securities” as (i) monies derived by a municipal entity from the sale of municipal securities, (ii) investment income derived from the investment or reinvestment of such monies, (iii) any monies of a municipal entity or obligated person held in funds under legal documents for the municipal securities that are reasonably expected to be used as security or a source of payment for the payment of the debt service on the municipal securities, including reserves, sinking funds, and pledged funds created for such purpose, and (iv) the investment income derived from the investment or reinvestment of monies in such funds. Found inside – Page 633... with Federal Securities Laws Facilitate Access To Information Investors Need Align and Manage Resources 5 2 2 0 advisor registrations , and reviewing and processing rule filings by the MSRB related to municipal advisor regulation . 0000003237 00000 n An investment adviser to a pooled investment vehicle that contains proceeds of an issuance of municipal securities is required to register as a municipal advisor, absent an exemption. Independent Registered Municipal Advisor (IRMA) Exemption Notice This notice has been prepared and made available by the California Department of Transportation (Department) in response to the Securities and Exchange Commission's Rule 15Ba1‐1(d)(3)(vi)(B) (Municipal Advisor Rule) promulgated under the Securities Exchange Act of . First, the IRMA has to be registered as a municipal advisor and provide advice to the municipality on the same municipal securities issuance or municipal financial product. Similarly, swap dealers registered under the Commodity Exchange Act are not considered to be acting as municipal advisors when recommending a municipal derivative or a trading strategy that involves a municipal derivative. In other words, they are looking . Ȗ~���8���n�^�J�M�[,�@e�0�c{��2�<3���^�����&�����"��L m5Vr���y�ٛ��j�#���ۗ��r�QͿ��b��_ 0000016333 00000 n Attorneys who provide legal advice with respect to a municipal bond issuance to clients that are municipal entities, obligated persons or other participants in the transactions are exempt from registration. §78o-4) to add a new requirement that "municipal advisors" register with the SEC and MSRB (October 2010) -September 2013, the Commission adopted final rules for municipal advisor registration •Final Rules were to be effective on January 13, 2014 •January 13, 2014; the SEC temporarily stayed the Final Rules until July 1, 2014 advisor exemption to the Municipal Advisor Rule of the U.S. Securities and Exchange Commission (Rule 15Ba1-1-1(d)(3)(vi)). U.S.C. Found inside – Page 24-48Absent an exemption, the answer probably is no. Under case law, soliciting potential investors to purchase securities, and receiving transaction-based compensation (municipal advisors typically are paid from the proceeds of the ... State and local government employees, board members, committee members and others are specifically exempted from the Rule when acting in their official capacity. Found inside – Page 2-34The SEC has granted such exemptions in limited circumstances and following lengthy application processes. ... A registered broker-dealer or registered municipal advisor also must be subject to pay-to-play rules adopted by FINRA or the ... 0000015861 00000 n Registration of Municipal Advisors FAQs PDF. However, the exemption is limited only to those investment advisers that are registered with the SEC. On May 19, 2014, the Securities and Exchange Commission's ("SEC") Office of Municipal Securities updated its Frequently Asked Questions ("FAQs") regarding the municipal securities registration rules discussed in our prior Banking and Financial Services E*Lert of October 17, 2013. 0 Municipal advisors are required to register with the SEC, are subject to the supervision of the Municipal Securities Rulemaking Board (“MSRB”), and have an explicit fiduciary duty to their clients. financial advisor "could" constitute municipal advisory activities for which registration or another exemption would be required. The Municipal Advisor Rule (MA Rule) approved by the Securities and Exchange Commission (SEC) went into effect on July 1, 2014. 0000053089 00000 n The broadest exemption in the Rule is the provision that anyone may be exempt from the definition of municipal advisor if the municipal entity or obligated person has engaged an independent registered investment adviser (“IRMA”). Lisa Lopez. Professionals that do not have a fiduciary duty to the client may only provide advice pursuant to an exemption or exception. Independent Registered Municipal Advisor Exemption. In The Handbook of Municipal Bonds, editors Sylvan Feldstein and Frank Fabozzi provide traders, bankers, and advisors—among other industry participants—with a well-rounded look at the industry of tax-exempt municipal bonds. 0000014277 00000 n 0000004881 00000 n Found inside – Page 469( iii ) Certain types of municipal advisors . Under section 15B ( e ) ( 4 ) ( B ) of the Act ( 15 U.S.C. 780-4 ( e ) ( 4 ) ( B ) ) , municipal advisors include , without ... ( 3 ) Exemptions from municipal advisor definition . Municipal Advisor Rule Exemption - Bonds. In its adopting release, the SEC said that the rule was meant to “mitigate some of the problems observed with the conduct of some municipal advisors, including ‘pay to play’ practices, undisclosed conflicts of interest, advice rendered by financial advisors without adequate training or qualifications, and failure to place the duty of loyalty to their clients ahead of their own interests.”. Under the Act and SEC and MSRB rules, an MA owes a statutory fiduciary duty to its municipal client, including a duty of care and a duty of loyalty. Found inside – Page 2628[ 31MRI Trucking industry : exempt drivers used by motor carriers from certain regulations if transporting grapes ... ( 5JA ) Wall Street Reform and Consumer Protection Act : clarify provisions relative to regulation of municipal advisors ... financial advisor "could" constitute municipal advisory activities for which registration or another exemption would be required. July 21, 2021 To Whom it May Concern: CRAA has retained an independent registered municipal advisor. Independent Registered Municipal Advisor Exemption dated 4/2/2020. Further, the MA Rule mandates that professionals that provide advice on the sale of bonds or investment of bond proceeds maintain a fiduciary duty to their clients. 0000011721 00000 n [1] Responses to these FAQs were prepared by and represent the . Exclusions and Exemptions. Deposit accounts and other short term investments, like sweep accounts and CDs; Extensions of credit to a municipality or obligated person (including issuing letters of credit or direct purchases of municipal securities by the bank); and. SEC Municipal Advisor Rule - Evidence of IRMA Exception. INTRODUCTION . NEW YORK — Municipal advisors remain concerned about one of the key exemptions to the Securities and Exchange Commission's municipal advisor registration rule, even though they said . 0000016377 00000 n SEC Clarifies Bank Exemptions in Municipal Advisor Registration FAQs. This exclusion only applies to activities within the scope of an underwriting, including advice on the structure, timing, terms and other similar matters in the context of a specific issuance. 0000018126 00000 n So confusing, in fact that the feds delayed implementating the Municipal Advisor Rule by half a year to July 1. 19 0000008160 00000 n Municipal advisors must register with the SEC and owe a fiduciary duty to municipal entities. These services include: Additionally, banks are not required to register as municipal advisors for investments made by the bank while acting in the capacity of an indenture trustee or similar capacity. Found inside – Page 104Will the SEC's final municipal advisor rule be consistent with the bipartisan legislation the House passed last year ? ... Dodd - Frank are exempted from having to register under the Investment Advisers Act . As investment advisors ... a. July 12, 2016. 80b-3(b)(3)), or that is an exempt reporting adviser, as defined in section 275.204-4(a), to provide investment advisory services for . [1] A “municipal entity” is a state or local governmental entity with the power to issue municipal securities. As of May 11, 2021 . Common Misconceptions About the Municipal Advisor Rule December 17, 2013 1. . Found inside – Page 406In early July , the Commission's rules providing for the regulation and registration of municipal advisors will become ... However , FAQ's detailing the manner in which the rule treats wholly owned bank subsidiaries making tax exempt ... By publicly posting the following written disclosure, Sarasota County intends that market participants receive and use it for purposes of the independent registered municipal advisor exemption to the SEC Municipal Advisor Rule. 0000016462 00000 n On October 18, 2013, the Securities and Exchange Commission (SEC) approved the Municipal Advisor Rule (MA Rule), addressing the deinition, registration, and regulation of municipal advisors. SEC Clarifies Bank Exemptions in Municipal Advisor Registration FAQs. Therefore, all non-SEC registered . Washington County has retained as Registered Municipal Advisors, Springsted Inc. and as Registered Investment Advisor Patterson & Associates. • The municipal advisor discovered the triggering political contribution within four months of the date of the contribution. H�|�_k�0�����Q�%5N$0��������M��`�e�8��ӹJZ��>�`�s��n�w��ϼ��F�3���S8���߇C�T��n>����N�ʛw��9�؍�iX�;�sz�W�w���_}��c���/�zz��Z|�>t���|H}"m[ The following people conducting the specified activities would not be required to register as a municipal advisor: Public Officials and Employees. Engineers Receive Broadened Exemption from New SEC Municipal Advisor Rules ACEC Efforts Clarify Engineering Exemption WASHINGTON, DC (SEPTEMBER 30, 2013)—Final municipal advisor registration rules just adoptedby the Securities and Exchange Commission (SEC) significantly broadens the engineering exemption—thanks to [5]  Third, the IRMA has to be independent, which means that it is not, and has not been within the past two years, associated with the person seeking to rely on this exemption. This is not a blanket exemption, however. trailer Registered investment advisorss providing advice on the investment of municipal bond proceeds or municipal escrow investments will be exempted from registering as municipal advisors under final. The City is represented by PRAG, WHD will continue to enforce the 2004 part 541 regulations through December 31, 2019, including the $455 per week standard salary level and $100,000 annual compensation . 0000019118 00000 n An adviser to such a pool is required to register as a municipal advisor, unless an exemption applies. N.E. The rule contains a number of exclusions (relating to the role of a specific party) as well as exemptions (primarily . The Port will determine whether to consider advice and proposals with our . 0000021768 00000 n If the investment adviser does not meet SEC statutory criteria, the investment adviser must be registered or licensed by a state, unless otherwise exempt. There are exemptions that allow finance professionals to furnish advice to municipal issuers without acting as a fiduciary. The Rule is complicated and its full implications cannot be fully discussed in this article. Similarly, broker-dealers may be excluded from the definition of municipal adviser as long as they are serving as an underwriter of a specific municipal securities issue, under Rule 15Ba1- 1(2)(i). %%EOF 0000003735 00000 n Found inside – Page 6-52This Rule applies when a broker-dealer is not required to register with the SEC as a municipal advisor, ... it applies when the brokerdealer acts for an SEC-registered adviser or a foreign private adviser exempt for such registration. Found inside – Page 403(4) The Commission, by rule or order, upon its own motion or upon application, may conditionally or unconditionally exempt any broker, dealer, municipal securities dealer, or municipal advisor or class of brokers, dealers, municipal ... A Municipal Advisor may wish to take advantage of the Rule by offering to provide a specified set of services, such as review of a certain number of proposals, for a regular, but relatively modest retainer, so that the Borrower can have the benefit of both the IRMA exception and the Municipal Advisor's review of proposals, and the Municipal . 0000008850 00000 n On September 18, 2013, the SEC approved its final municipal advisor registration rule, which took effect on July 1, 2014. By publicly posting this written disclosure, the County intends that market participants receive and use it for purposes of determining compliance with the independent registered municipal advisor exemption to the SEC Municipal Advisor Rule. 3. A person does not have to be compensated for advice under the Rule. An RFP or RFQ must be current – not outstanding longer than six months – and either distributed to at least three competitive firms or posted publicly. The exclusion allows advisers to provide advice on how to invest the proceeds of a municipal bond issuance, but does not allow them to provide guidance concerning the structure, timing and terms of the bond issue. SEC Municipal Advisor Rule . Additionally, municipal advisors are now subject to extensive regulatory obligations, including disclosure, record keeping, and compliance with pay-to-play rules (similar to those applicable to municipal dealers and investment advisers). Found inside – Page 11240.15Ba2-6 [ Reserved ] 240.15Ba2-6T Temporary registration as a municipal advisor ; required amendments ... EXEMPTION OF CERTAIN TRANSACTIONS FROM SECTION 16 ( B ) 240.16b - 1 Transactions approved by a regulatory authority . Found inside – Page 500( 4 ) The Commission , by rule or order , upon its own motion or upon application , may conditionally or unconditionally exempt any broker , dealer , municipal securities dealer , or municipal advisor , or class of brokers , dealers ... 0000006513 00000 n An underwriter may also provide recommendations in response to a request for proposal (RFP) or a request for qualifications (RFQ). SIFMA lawsuit targeting muni advisor exemption may turn on court's authority to rule on it By Sarah Wynn January 26, 2021, 12 . Commodity trading advisors registered with under the Commodity Exchange Act are also excluded from the definition of municipal advisor, to the extent they provide advice related to swaps. Fax: 1.724.935.6790. Among other things, the . 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