Employees of a joint-venture broker-dealer, who previously worked for and remain "associated persons" with the two legacy firms that created and control the joint venture, may solicit municipal securities business on behalf of each of their legacy firms without triggering Rule's G-38 prohibition against broker-dealers using independent consultants, the Municipal Securities Rulemaking Board said in recent guidance.

In a three-page interpretative letter, the MSRB also said that each employee would only be considered a municipal finance professional of the legacy firm for which it solicits muni business, not both legacy firms.

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