The MSRB has requested that the SEC approve the proposed interim assessment for effectiveness on October 1, 2011. Comments on the assessment should be submitted to the SEC. The MSRB expects the interim assessment to remain in effect for a limited period of time during which the MSRB will decide whether to make the interim assessment permanent after it receives comments on the draft survey on municipal advisory activities.
MSRB is attempting to more equitably collect the revenues it needs. Presently, virtually all of the funds are collected from broker-dealers. Even after the imposition of these fees over 90 percent of the revenue will be collected from broker-dealers.
The MSRB has proposed this fee even though the definition of municipal advisor is not settled and it is not clear just who is a municipal advisor, The BDA understands, however, that the definition will be finalized sometime this fall, hopefully before the assessments are sent out by the MSRB. Click here to view proposed form A-11 Interim. Instructions for the form can be found here.
The MSRB is also seeking comment on a draft survey gathering information from municipal advisors on the nature of the municipal advisory activities they undertake as well as the manner and level of compensation received by municipal advisors for such municipal advisory activities (the “draft survey”). Comments on the draft survey should be submitted to the MSRB by no later than September 12, 2011. To find the form for the Draft Survey, click here.
To view the MSRB submission to the SEC, click here.