Separately Identifiable Department or Division of Bank


As a general matter, when a branch or division of a legal entity conducts business that requires broker-dealer or investment adviser registration, the entire legal entity becomes subject to registration and the related regulatory requirements. However, in the case of a bank acting as a municipal securities dealer or advisor, or as an investment adviser, it is possible for only a "separately identifiable division or department" of the bank to register so that the remainder of the bank is not subject to the full menu of regulatory requirements. Operating in this manner requires that the bank establish procedures to clearly demarcate the activities conducted in the separately identifiable department or division from those conducted by the rest of the bank.

See also the topic pages on the Muni Advisor Registration Process and the Broker-Dealer Registration Process.'s picture
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Rules Relating to Muni Firms

  • SEA Rule 15Ba1-1(d)(4) (Definitions and "special rule for separately identifiable departments or divisions of banks for municipal advisory purposes")
  • SEA Rule 15Ba2-1 (Registration of bank or bank department as muni dealer)
  • MSRB Rule D-8 (Definition of "bank dealer")
  • MSRB Rule G-1 (Separately identifiable department or division of a bank)


Regulatory Assistance




Broker-Dealer Guide