SIFMA Opposes Proposed Requirement that Certain Individuals Take MSRB Series 50 Examination

SIFMA submitted a comment letter to the SEC opposing the MSRB's rule proposal regarding the selection of examination questions and content outline for the Municipal Advisory Representative Qualification Examination (the "Series 50 Examination").

SIFMA joined ICI in opposing the requirement that individuals who advise solely on municipal fund securities, including advising a state on 529 college savings plans, must take a Series 50 Examination. SIFMA asserted that the Series 50 Examination is designed to test competencies that are unrelated to municipal fund securities advice. According to SIFMA, only the first section, which contains 12 questions on understanding SEC and MSRB rules regarding municipal advisers, pertains to a municipal advisor representative who advises exclusively on municipal fund securities.

SIFMA stated that it does not believe that a municipal advisor who "renders no advice whatsoever" related to municipal securities should be "forced to demonstrate competencies."