MSRB seeks comment on draft amendments to retire financial advisor terminology

MSRB Board Vice Chair Wendell Gaertner
MSRB Board Vice Chair Wendell Gaertner

The Municipal Securities Rulemaking Board is seeking comment on draft amendments that would modernize language in MSRB rules by retiring financial advisor terminology and adopting the uniform term "municipal advisor" instead. 

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The MSRB's request for comment, published on April 23, seeks input on draft amendments to MSRB Rules G-1, G-3, G-20, G-23 and G-37 to eliminate references to the terms "financial advisor" or "financial advisory and consultant services" in references to dealers serving in such a financial advisory capacity. The comment submission deadline is July 20. 

Harmonizing terms across multiple rules ensures that the MSRB remains consistent with the terminology set forth under the Dodd-Frank Wall Street Reform and Consumer Protection Act and used in MSRB rules adopted since the act's passage, the MSRB said in a press release. Dodd-Frank was signed into law in 2010. 

The request for comment "represents the first phase of MSRB's Municipal Advisor Retrospective Rule Review process – one made more effective with robust feedback and collaboration from stakeholders," MSRB Board Vice Chair Wendell Gaertner said in the April 23 release.

"Retiring these terms eliminates unnecessary ambiguities associated with their use in MSRB rules, modernizes the language and streamlines our rules to reduce the compliance burdens for municipal advisors," Gaertner said. 

In addition to seeking comment regarding the draft amendments, the MSRB is seeking "input more broadly from the municipal advisor community, the municipal entity and obligated person clientele they serve, and other municipal market stakeholders on the scope and approach toward undertaking this retrospective review," the RFC said. 

"MSRB launched its Municipal Advisor Retrospective Rule Review to ensure our regulatory framework keeps pace with how the market works," MSRB Chief Regulatory and Policy Officer Ernesto Lanza said. "We look forward to receiving stakeholder feedback and engaging with market participants as we begin this important process." 

The Bond Dealers of America "appreciates the MSRB's efforts to update and modernize its rule book, including the proposal to eliminate the use of the term financial advisor, an obsolete term," Michael Decker, senior vice president for research and public policy at BDA, said in an April 23 statement. 

"We look forward to reviewing the proposal in detail and providing comments," Decker said. 

In a separate press release issued April 23, the MSRB announced discussion topics for the board's third quarterly meeting of fiscal year 2026, set to be held on April 29 and April 30. 

Board discussion of regulatory topics is expected to include a reviewing of comment letters received in response to an RFC the MSRB published Jan. 14 regarding potential amendments to MSRB Rule G-27 on dealer supervision. Discussion is also expected to include a reviewing of comment letters received in response to an RFC the MSRB published in November 2025 that sought comment on draft amendments to MSRB Rule D-15, which defines the term sophisticated municipal market professional. 

Also during the meeting, the board is expected to review stakeholder feedback on a concept release regarding the potential modernization of disclosure obligations associated with municipal fund securities.

The board is also slated to receive updates on market transparency and public accountability initiatives, the release said. Those updates will include an update on the modernization of the Electronic Municipal Market Access website. 


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