SIFMA updated its model disclosure documents and drafting guidance to improve municipal security underwriter compliance with updated requirements under an MSRB rule on dealer conduct MSRB Rule G-17 ("Conduct of Municipal Securities and Municipal Advisory Activities").
SIFMA's G-17 model disclosure documents and drafting guidance are comprised of two disclosure letters that reflect underwriters' amended fair dealing obligations. According to SIFMA, the disclosure letters apply to:
"Sole or Senior Managing" underwriters for the purposes of (i) making standard disclosures and (ii) self-disclosure of conflicts; and
co-managing underwriters regarding self-disclosure of conflicts.
Additionally, SIFMA encouraged underwriters to (i) update relevant internal processes in connection with the revised model disclosure documents and (ii) continue to inform clients and public finance departments of upcoming compliance changes. SIFMA stated that it intends to amend its Model Risk Disclosures before the recently extended March 31, 2021 compliance date announced by the MSRB.
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