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MSRB Proposes Extensions of Temporary Relief in Light of COVID-19 Pandemic

The MSRB requested immediate authorization from the SEC to provide extended regulatory relief to firms due to COVID-19-related disruptions to "normal business operations." The MSRB requested delaying compliance with:

  • amendments to MSRB Rule G-32 ("Disclosures in Connection with Primary Offerings"), requiring submission of additional data concerning primary offerings of municipal securities;
  • amendments to MSRB Rule G-17 ("Conduct of Municipal Securities and Municipal Advisory Activities"), regarding the fair dealing obligations that underwriters owe to municipal securities issuers (see previous coverage);
  • MSRB Rule G-3 ("Professional Qualification Requirements"), with respect to (i) individuals passing certain qualification exams and continuing education requirements, and (ii) firms conducting an annual needs analysis and providing continuing education content (see previous coverage);
  • MSRB Rule G-27 ("Supervision"), with respect to (i) firms conducting an annual compliance meeting and branch inspections, and (ii) a firm submitting an annual report reviewing its supervisory controls; and
  • MSRB Rule G-44 ("Supervisory and Compliance Obligations of Municipal Advisors"), requiring a municipal advisor to provide an annual certification regarding compliance with policies and procedures.

In addition, the MSRB requested that the SEC permit the waiving of any "registration, annual and market activity-based" fees that are payable between March 1, 2020 and July 31, 2020.

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