Placement Agent Activities of Municipal Advisors

SIFMA provides its views in response to the letter to the U.S. Securities and Exchange Commission (SEC) from the National Association of Municipal Advisors (“NAMA”) dated December 15, 2014 (the “NAMA Letter”). In the NAMA Letter, NAMA requests that the SEC exempt registered municipal advisors from being required to register as broker-dealers or as investment advisers in connection with specified municipal advisory activities.

SIFMA strongly disagrees with NAMA’s position that a financial advisor should be exempt from registration as either a broker-dealer or investment adviser solely on the basis of its registration as a municipal advisor. NAMA’s request reflects a fundamental misunderstanding of the investor protection goals of broker-dealer and investment adviser regulation. Providing the exemptions that NAMA requests would create significant gaps in the regulatory protections that are currently afforded to potential investors in municipal securities and to municipal entities seeking advice regarding the investment of bond proceeds.