MSRB Asks if its Rules Are Unfair to Small Firms

The MSRB issued a Request for Information ("RFI") asking whether its rules may result in "undue regulatory, compliance, operational or administrative burdens or other negative unintended impacts on smaller regulated entities."

In the RFI, the MSRB said that it is seeking input targeting the experiences of smaller regulated entities on market practices - as compared to mid-sized or larger regulated entities - that could have an impact on the regulatory or market transparency activities of the MSRB. The MSRB stated that the Exchange Act prohibits the MSRB from imposing a regulatory burden "on small municipal advisors that is not necessary or appropriate in the public interest . . . . " The MSRB also stated that the RFI "should not be construed as a determination by the MSRB to adopt, amend, delete, or consolidate any of its rules or guidance."

The MSRB asks responders to identify rules, interpretive guidance or other MSRB activity when answering 11 open-ended questions on the impact of the MSRB's rules on small firms.