This is a reminder that SEC Rules 15Ba1-1 through 15Ba1-8 and Rule 15Bc4-1 and Forms MA, MA-I, MA-W, and MA-NR become effective on July 1, 2014, which is the start of the permanent registration regime for municipal advisors. The registration process is staggered based upon the temporary registration number received when municipal advisors initially filed Form MA-T:
|Temporary Registration Number Range||Period for Filing|
|866-00001-00 through 866-00400-00||7/1/2014-7/31/2014|
|866-00401-00 through 866-00800-00||8/1/2014 – 8/31/2014|
|866-00801-00 through 866-01200-00||9/1/2014 – 9/30/2014|
|After 866-01200-00||10/1/2014 – 10/31/2014|
Form MA, and a Form MA-I for each natural associated person, must be submitted electronically through EDGAR. Firms that are not already authorized users of EDGAR must obtain authorization to become an EDGAR filer. Upon filing, the SEC will have up to 45 days to declare the registration effective.
In addition, the recordkeeping requirements set forth under Rule 15Ba1-8 will be effective on July 1, 2014, which requires registered municipal advisors to maintain certain records for at least five years, including incoming and outgoing communications relating to municipal advisory activities, policies and procedures, and any documents created that were material to making a recommendation to a municipal entity or obligated person or that memorializes the basis for that recommendation.
ACA’s Free Webcast on July 15
ACA Compliance Group is providing a free webcast on July 15, 2014 at 11:00 AM EDT to discuss SEC registration requirements and proposed MSRB rules for municipal advisors. If you are interested in participating, please click this link.
For more information on how ACA Compliance Group can assist municipal advisors, please contact: