Alaric Compliance Alert: MSRB 4th Quarter Compliance Deadlines
In the MSRB Fall 2019 Compliance Corner, the following key compliance deadlines were discussed. 1
Dealers and municipal advisors should note the following key compliance dates and deadlines relevant through the fourth quarter of calendar year 2019.
October 31, 2019: Political Contributions Quarterly Disclosures (MA/BD)
MSRB-regulated entities must submit information to the MSRB through Form G-37 on their municipal securities and advisory business and related political contributions to municipal entity officials, state and local political parties, and bond ballot campaigns. Read instructions for Form G-37.
October 31, 2019: Payment Due for Annual MSRB Registration Fee (MA/BD)
As part of its initial registration and annually thereafter, based on the fiscal year of the Board, each broker, dealer, municipal securities dealer and municipal advisor shall pay to the Board an annual registration fee of $1,000. The annual registration fee shall be payable in the manner provided by the MSRB Registration Manual. See MSRB Rule A-12.
December 31, 2019: Investor and Municipal Advisory Client Education Notifications (MA/BD)
All dealers and municipal advisors must provide a written notification to customers and municipal advisory clients with a statement that they are registered with the MSRB and the Securities and Exchange Commission (SEC); the MSRBs website address; and a statement as to the availability of the Information for Municipal Securities Investors and/or Information for Municipal Advisory Clients brochures. This notification must be provided once each year. See MSRB Rule G-10.
December 31, 2019: SEC Form MA Verification (MA)
Within 90 calendar days after a municipal advisor firms fiscal year end (calendar year end for sole proprietors), the municipal advisor firm must file an annual update, which is an amendment to the municipal advisor firms SEC Form MA, that either confirms the information is accurate or updates responses to any item for which the information is no longer accurate. See SEC Rule § 240.15Ba1-5.
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