SIFMA Submits Comments to SEC Regarding MSRB-Proposed Amendments to Continuing Education Requirements

SIFMA submitted comments to the SEC regarding the MSRB proposal to amend MSRB Rule G-3. The comment concerns continuing education requirements and in part, recommends that MSRB focus its efforts on the newly regulated/previously unregulated financial advisors.

Regarding MSRB's proposal, SIFMA provided four recommendations to the SEC that included the following:

• MSRB should not de-harmonize its continuing education requirements from FINRA rules. SIFMA explained that existing MSRB continuing education requirements are harmonized with FINRA's Rule 1250(b) ("Firm Element Continuing Education Requirements");
• MSRB should not expand the application of Firm Element Continuing Education to Non-Customer Facing Registered Representatives. SIFMA explained that the proposed amendments would result in a distinct educational module for personnel without customer contact. Furthermore, SIFMA noted, the MSRB has not demonstrated a compelling need to subject these individuals to additional training and education, or that the type of training proposed would be relevant to their particular job functions;
• MSRB should clarify the specific effective date; and
• MSRB should focus its efforts on the newly regulated/previously unregulated financial advisors to establish a minimum threshold of training annually that is appropriate to the public interest and for the protection of investors, municipal entities or obligated persons.

See: SIFMA Comment Letter.