Draft Amendments to Retire Financial Advisor Terminology
Summary
SIFMA 1 provided comments to the Municipal Securities Rulemaking Board (MSRB) Notice 2026-03, which requests input on draft amendments to MSRB Rules G-1, G-3, G-20, G-23, and G-37 to replace legacy references to “financial advisor” with the term “municipal advisor.”
Excerpt
SIFMA and its members strongly support the MSRB’s retrospective review initiative and its efforts to modernize the rulebook to better align with the statutory and regulatory framework established under the Dodd-Frank Act. As the MSRB notes, the continued use of both “financial advisor” and “municipal advisor” terminology may introduce ambiguity and unnecessary compliance burdens.
Overall, SIFMA supports the MSRB’s objective of promoting clarity and consistency in terminology, provided that the amendments do not inadvertently alter the scope or application of existing requirements.
I. General Comments
SIFMA agrees that harmonizing terminology across MSRB rules to reflect the “municipal advisor” construct established under the Exchange Act would improve clarity and reduce the risk of inconsistent interpretations. However, we urge the MSRB to ensure that:
- The amendments do not expand the substantive scope of any rule, particularly with respect to dealer obligations;
- Existing distinctions between dealer and municipal advisor activity are preserved; and
- Interpretive guidance is updated comprehensively to avoid uncertainty.
We also encourage the MSRB to explicitly reaffirm, in any adopting release, that these changes are not intended to modify existing regulatory expectations or create new compliance obligations, consistent with the Notice’s stated intent.
- SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).