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The MSRB updated its FAQs for regulated entities concerning COVID-19-related regulatory relief. The additional guidance addresses the application of a recent SEC Order granting temporary conditional relief to registered municipal advisors soliciting certain qualified providers for direct placements by municipal issuers in light of MSRB Rule G-23 (see prior coverage here and here).
The FAQs address, among other things:
- relief from examination requirements under MSRB Rule G-3 ("Professional Qualification Requirements");
- supervisory considerations under MSRB Rule G-27 ("Supervision");
- transaction reporting obligations under Federal Reserve Board facilities;
- the process for providing customers with markup disclosures pursuant to MSRB Rule G-15 ("Confirmation, Clearance, Settlement and Other Uniform Practice Requirements with Respect to Transactions with Customers"); and
- best execution obligations under MSRB Rule G-18 ("Best Execution") and fair pricing obligations under MSRB Rule G-30 ("Prices and Commissions").
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