MSRB Rule G-21 on Advertising
SIFMA and its members appreciate the MSRB’s efforts to update MSRB Rule G-21. We agree with the principles in the rules that communications to the public must be consistent with fair dealing duties and in good faith, must be fair and balanced, and must provide a sound basis for evaluating the facts in regard to any particular security. We are pleased that, at long last, there will be a leveling of the regulatory playing field between brokers, dealers, and municipal securities dealers (collectively, “dealers”), who have long been regulated by MSRB Rule G-21, and non-dealer municipal advisors, whose advertising activities will become regulated under new MSRB Rule G-40. We agree that the MSRB should have two rules on public communications, and we believe the rules should be divided based on activity, not by registration category. We do feel, however, that FINRA Rule 2210 should be incorporated by reference into Rule G-21, or at a minimum the two rules should be more closely harmonized.
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