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Tuesday, April 13, 2021
On Wednesday, March 17, 2021, the Municipal Securities Rulemaking Board (“MSRB”) proposed new Rule G-46 to codify the “fair dealing …obligations” of “solicitor municipal advisors” (“SAM’s;” not to be confused with Surface to Air Missiles). The MSRB Notice states that municipal advisors generally and SAM’s, in particular, were not subject to regulatory oversight until the Dodd-Frank Act was passed in 2010 in response to the Great Recession of 2007-2009. The MSRB is a self-regulatory organization (somewhat like the Financial Institutions Regulatory Authority [“FINRA”]) created in 1975 under Section 15 B of the Securities Exchange Act of 1934, as amended, and subject to the oversight of the Securities and Exchange Commission (“SEC”). The MSRB Notice requests comments on the proposed new regulation by Thursday, June 17, 2021. Accordingly for those persons and entities that participate in the market for selling municipal