ABA has released additional staff summaries for member banks on the final municipal adviser rule that the Securities and Exchange Commission adopted in September. The summaries cover key definitions and exemptions, and offer a decision tree to help bankers understand if they will need to register under the rule.
Additional versions of the summary are intended to help trust departments and broker-dealers understand the rule, which will take effect 60 days after its publication in the Federal Register.
The final rule narrows the scope of who must register as a municipal adviser by more narrowly defining what constitutes “investment strategies” that a municipal adviser gives advice on. It also provides exemptions for many traditional banking products and services. Individuals working for a registered municipal advisory firm do not need to individually register as a municipal adviser, but may rely on their firm’s registration.