Municipal Securities Regulation and Enforcement: Year in Review 2019

The second half of 2019 saw U.S. Securities and Exchange Commission (SEC) enforcement activity focused on municipal adviser registration and investor protections in addition to continued review of Municipal Securities Rulemaking Board (MSRB) rules and guidance.

Of particular note across the municipal securities industry is the pending request by the market leader in municipal advisory services, PFM Financial Advisors LLC (PFM), from October 2018 to the SEC’s Division of Trading and Markets and the SEC’s Office of Municipal Securities seeking interpretive guidance that a non-dealer municipal adviser would not be required to register as a broker-dealer if it engages in certain specified activities related to direct placements of municipal debt.

In the second half of 2019, the MSRB announced the effective date of rule changes for MSRB Rules G-11 and G-32, approved amendments to underwriters’ fair dealing obligations under Rule G-17, and eliminated certain CUSIP requirements under Rule G-34.

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