SEC Municipal Advisor Registration Rules and Forms
Summary
SIFMA provided comments to the U.S. Securities and Exchange Commission (SEC) on municipal advisor registration rules and forms, urging the SEC to modernize and streamline filing requirements, more accurately assess compliance burdens, and address duplicative or outdated regulatory requirements.
Excerpt
SIFMA 1 writes in response to the Commission’s request for comment 2 issued pursuant to the Paperwork Reduction Act (“PRA”) on the existing collection of information provided for under Commission Rules 15Ba1–1 to 15Ba1–8 and Forms MA, MA–I, MA–W, and MA–NR, 3 which require municipal advisors to submit and maintain certain information to register with the Commission and to withdraw their registration.
The Commission has invited comments on (a) whether the proposed collection of information is necessary for the proper performance of the functions of the Commission, including whether the information will have practical utility; (b) the accuracy of the Commission’s estimate of the burden imposed by the proposed collection of information, including the validity of the methodology and the assumptions used; (c) ways to enhance the quality, utility, and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on respondents, including through the use of automated, electronic collection techniques or other forms of information technology. SIFMA appreciates that the Commission also invited written comments on enumerated questions, which SIFMA addresses in Appendix A hereto.
SIFMA’s views on Rules 15Ba1–1 to 15Ba1–8 and Forms MA, MA–I, MA–W, and MA–NR follow along the same viewpoints previously submitted in our comment letters 4 to the Commission in response to the 60-day and 30-day notices on Rules 15Ba2–1 and 15Bc3–1 and Forms MSD and MSDW published in the Federal Register on June 12, 2025, 5 and August 11, 2025, 6 respectively. The Commission vastly underestimates the burden imposed by the information municipal advisors are required to submit to the Commission pursuant to relevant municipal advisor rules and forms.
We appreciate that the Commission is taking this opportunity to study whether to update municipal advisor registration rules to modernize associated filing requirements, consistent with its statutory obligations under the PRA. At the conclusion of its review of these issues, the Commission will recognize that updating these rules, forms, and filing requirements is consistent with its other recent initiatives to reduce unduly burdensome regulatory requirements imposed on market participants.
Beyond the required PRA review, we recommend the Commission conduct a complete retrospective rule review of Rules 15Ba1–1 to 15Ba1–8, and associated forms, as the municipal advisor registration regime is unnecessarily complex and burdensome, and should be streamlined to appropriately balance these burdens with the benefits of the rules. Although municipal advisor registration is not in the news on a daily basis, this type of retrospective rule review and associated rulemaking to right-size the rules—minimizing regulatory burdens while ensuring the Commission and the public have access to relevant material information—is the necessary “blocking and tackling” the Commission must periodically undertake to ensure its rules remain current as market conditions, technologies, and methodologies for providing access to information change. The Commission should undertake these reviews and revise its rules where the reviews identify unreasonably burdensome, duplicative, or outdated requirements, across market participants in all of the various asset classes the Commission regulates.
SIFMA also recommends that the Commission work with other federal financial regulators to identify and eliminate potential regulatory duplication, consistent with the Commission’s recent initiatives to harmonize regulatory approaches across the federal government. Therefore, we encourage the Commission to consider the benefits of reviewing and harmonizing potentially duplicative regulatory requirements that exist across the rule sets of the Commission, the MSRB, FINRA, and the federal banking regulators.
- 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 one million employees, we advocate on 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). For more information, visit http://www.sifma.org.
- 91 FR 40622 (July 2, 2026) (“Notice”). Any terms not defined herein have the same meaning as in the Notice.
- Rules 15Ba1–1 to 15Ba1–8 (17 CFR 240.15Ba1–1 to 17 CFR 240.15Ba1–8) and Forms MA (17 CFR 249.1300), MA–I (17 CFR 249.1310), MA–W (17 CFR 249.1320), and MA–NR (17 CFR 249.1330) under the Securities Exchange Act of 1934 (15 U.S.C. 78a et seq.) (the “Exchange Act”).
- Letters from Leslie M. Norwood, Managing Director and Associate General Counsel, and Gerald O’Hara, Vice President and Assistant General Counsel, SIFMA, dated Aug. 11, 2025, https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202505-3235-013, and Oct. 9, 2025, https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202505-3235-013.
- 90 FR 24835 (June 12, 2025).
- 90 FR 43275 (Sept. 8, 2025).