MSRB Provides Guidance on Continuing Education Requirements for Municipal Advisors
The MSRB provided answers to frequently asked questions ("FAQs") on the continuing education requirements for municipal advisors under MSRB Rule G-3 (see previous coverage).
The FAQs included the following:
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Municipal advisors will have until December 31, 2018 to conduct a needs analysis and develop a written training plan;
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Municipal advisors must provide training on fiduciary duty obligations owed to municipal entities regardless of whether they have municipal entities as clients;
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There is no minimum hour requirement for a continuing education program;
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Sole proprietors have considerable flexibility in implementing continuing education requirements, including the option to utilize existing content to save costs;
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All covered persons must participate in the continuing education program;
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Firms may disseminate materials to covered persons from a webinar attended by one such covered person;
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There is no specific type of training required for municipal advisor principals; rather, a firm may determine that training in specific areas is needed and appropriate based on its needs analysis;
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Municipal advisors may use vendors to administer continuing educations programs, although municipal advisors retain responsibility for full compliance;
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Dealer-municipal advisors must conduct separate needs analyses for their municipal advisory activities and dealer activities;
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Municipal advisors must maintain evidence that covered persons completed training programs; and
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Municipal advisors must document the content of their training programs.
The FAQs also contain additional resources and materials that support compliance with continuing education requirements.