The request for comment is available here. You can find BDA’s final letter here.
The MSRB’s proposed amendments would:
- Apply Rule G-20 to all municipal advisors, prohibiting gifts or gratuities in excess of $100 per person per year in relation to the municipal securities activities of the recipient’s employer
- Apply the related record-keeping requirements of MSRB Rules G-8 and G-9 to municipal advisors
- Add a new provision to explicitly prohibit MSRB regulated entities from expensing certain entertainment costs to municipal securities issuances
BDA expresses our general support for extending the provisions to non-dealer municipal advisors, stating that it will promote a level-playing field in the marketplace and serve as an appropriate balance of consistency in regulation between dealers and non-dealer municipal advisors. However, we request clarification on what constitutes an “entertainment expense” prohibited from reimbursement and what constitutes normal travel costs. The BDA also requests an alignment of recordkeeping requirements for municipal advisors and dealers.
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