SIFMA Submits Comment Letter to SEC Regarding MSRB Professional Qualification Requirements for Municipal Advisors

SIFMA submitted a comment letter to the SEC regarding the MSRB draft amendments to establish professional qualification requirements for municipal advisors.

SIFMA explained that persons who are qualified currently to perform municipal securities activities also should be qualified to perform municipal advisor activities. According to SIFMA, the proposed MSRB requirement for separate qualification examinations is unnecessary, since the two qualifications have "substantial overlap" in their functions.

Accordingly, SIFMA recommended that, if the MSRB proceeds with developing a new qualification examination for municipal advisor representatives, then associated persons who qualify currently to perform municipal securities activities should be grandfathered as municipal advisor representatives. This methodology, SIFMA explained, is consistent with other major changes to qualification examinations.

Additionally, SIFMA stated that the MSRB's cost-benefit analysis was inadequate. SIFMA recommended that a comprehensive analysis be completed prior to the SEC's approval of the draft amendments.

See: SIFMA Comment Letter.Related news: MSRB-Proposed Professional Qualification Standards for Municipal Advisors Published (Fed. Reg.) (December 5, 2014); MSRB Proposes Professional Qualification Standards for Municipal Advisors (November 19, 2014); MSRB Requests Comment on Extending Gifts Rule to Municipal Advisors (October 23, 2014); MSRB Requests Comments on Extending Pay-to-Play Rule to Municipal Advisors (Notice 2014-15) (August 18, 2014); MSRB Requests Comment on Revisions to Draft Rule on Municipal Advisor Standards of Conduct (Notice 2014-12) (July 23, 2014); SIFMA Submits Comments to MSRB Regarding Proposal on Establishing Professional Qualification Requirements for Municipal Advisors (May 19, 2014).