Draft Amendment to MSRB Rule G-38

ABA Contact: Sally Miller 202-663-5325
Published: MSRB Rule G-38

The proposed amendment would repeal existing rule G-38 relating to consultants and replace it with a requirement that paid solicitations of municipal securities business on behalf of a dealer be undertaken only by associated persons of that dealer.

ABASA's concern focuses largely on the ability of bankers to discuss financing options with clients without triggering MSRB Rule G-37; and, therefore, those bankers would likely have no other municipal securities responsibilities. Accordingly, ABASA strongly believes that the act of soliciting municipal securities business (without more) should not require qualification as a municipal securities representative.

2004 Regulations Chart
Federal Register
Comment Letter