The SEC approved MSRB changes to MSRB Rule G-34 (CUSIP Numbers). The changes clarify that (i) broker-dealers and municipal securities dealers are subject to CUSIP requirements when acting as placement agents in private placements of municipal securities, and (ii) all municipal advisors are subject to CUSIP requirements. The changes include a "principles-based exception" (see previous coverage) to the CUSIP requirements. This exception would apply under certain circumstances when the buyer is a bank or bank affiliate that the seller reasonably believes is buying the bonds with an intent to hold those bonds until maturity.

The changes will become effective on June 14, 2018.

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