The MSRB will institute continuing education ("CE") requirements (see previous coverage) that obligate municipal advisors to "remain current in their industry knowledge." The SEC-approved requirements were developed in order to fulfill Dodd-Frank mandates and will be codified in amendments to MSRB Rules G-3 and G-8.
On an annual basis, each municipal advisory firm will be required to develop and implement a CE program that encompasses all "covered persons" (i.e., associated persons that are qualified as municipal advisor representatives or principals). Under the program, each firm must (i) conduct an analysis that assesses specific training needs, (ii) compose a written training plan, and (iii) deliver the training by the completion date. Firms also will have to document their compliance with all of the requirements.
The rule amendments will become effective on January 1, 2018. Firms will have until December 31, 2018 to complete the initial annual CE and recordkeeping requirements.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
