Proposed Rule G-42 would establish core standards of conduct for municipal advisors, provide guidance on the obligations and prohibitions that accompany their federal fiduciary duty to state and local governments, and clarify their duties of care and fair dealing to all clients.
BDA’s letter focuses on the following issues:
- Timing of disclosure of conflicts of interest
- Principal transactions
- Documentation of recommendations
- Reference to Rule G-23
- Reference to bank loans
The letter is available here.