MSRB Issues 2016 Compliance Advisory for Municipal Advisors

The MSRB issued its 2016 Compliance Advisory for Municipal Advisors. The advisory highlights compliance risks for municipal advisors and provides examples of conduct that could result in violations of various MSRB Rules, including the following:

• MSRB Rule A-12 ("Failure to Register with the MSRB")
• MSRB Rule G-3 ("Failure to Ensure That Associated Persons Are Properly Qualified")
• MSRB Rule G-44 ("Failure to Implement an Appropriate Compliance Program")
• MSRB Rules A-12, G-3, G-32 and G-34 ("Failure to Recognize When Placement Agent Activity May Be Brokerage Activity")
• MSRB Rule G-17 ("Failure to Deal Fairly with All Persons in the Conduct of Municipal Advisory Activities")

It also provides a list of factors to be considered by firms that are evaluating their compliance controls and implementing measures to mitigate their exposure to compliance risks.

The MSRB also intends for municipal advisors to use the Advisory as a tool for supplementing their assessment of the adequacy of their compliance programs.