NAIPFA PUBLIC AFFAIRS COMMITTEE NEWSLETTER SUBMISSION

Transcription

1 naipfa NOTABLE news National Association of Independent public finance advisors In this issue: NAIPFA PUBLIC AFFAIRS COMMITTEE NEWSLETTER SUBMISSION The Final MA Rule Effective Date January 13, 2014 JANUARY 13, 2014 is the date. It is not just any date. It is THE date! From this date forward the FINAL DEFINITION of a MA is implemented it is the date of the beginning for MA firms that have been wishing for the date to finally arrive it is the date of the beginning of the end for MA firms who fail to comply with the rules of a new era in the municipal securities industry it is the dawn of a new era it is the sunset of that which was it is the sunrise of the future it is the sunset of the past. The Report of the Public Affairs Committee A New Era A New Normal Everyone thinks of changing the world, but no one thinks of changing himself said Leo Tolstoy. Will Rogers was quoted as saying If Stupidity got us into this mess, then why can't it get us out? This seems to be the approach some municipal market participants have taken to MA Regulation. The broker and bank dealers were all for regulation of independent MA s, however their view of MA regulation took an abrupt turn when the SEC had the impudence to consider it only fair that if independent MA s should be regulated for providing advice to issuers of municipal bonds, then so should the employees of all firms who provide such advice. Yes, banks have been regulated as banks. Bank and broker dealers have been regulated as bank and broker dealer firms. However, the employees of independent firms, banks, and dealers have not until now been regulated as Municipal Advisors. A new era has come and a new normal will exist for all participants in the municipal securities industry. NAIPFA welcomes the future and a new beginning for issuers, investors, and those who safeguard the public trust. In this Report of the NAIPFA Public Affairs Committee, we focus the attention of our membership upon the dates which are of vital importance. We focus our membership upon events which will determine the future of the MA industry. We focus our membership upon events which will greatly influence the future of the municipal securities industry....continued on Page 3 Volume 2, Issue 11 NAIPFA Public Affairs Committee Submission Board Member Spotlight: Shelley J. Aronson 2013 NAIPFA Conference Wrap Up 3 President s Corner 5 1 1,3-8 2 December 13, 2013 Important Dates & Announcements: MSRB Education and Outreach, Atlanta, Georgia, January 28, NAIPFA Conference 2014: October 8th-10th in Portland, Oregon

2 BOARD MEMBER SPOTLIGHT Shelley J. Aronson, CIPFA NAIPFA Director-at- Large I like to picture myself at historic events: Lee and Grant at Appomattox (the winner would not have been apparent), to observe the grace and dignity exhibited at the end of such a horrible conflict. Playing poker with Harry Truman and the boys aboard the presidential yacht, especially the time that Winston Churchill dropped in. The Pilgrims' settlement, when Samoset strolls in and addresses them speaking the King's English. Where are you from or where did you grow up? Born in Manchester, NH, but (only partly) grew up on North Jersey Shore Bruce Springsteen country (if I had known that the Stone Pony in Asbury Park was going to become famous, I would have spent more time hanging around there). Summer nights were spent watching the moon rising behind us and banging those pleasure machines. Many lessons learned - when you're late for a meeting, tell em that the highway was jammed with broken heroes. What drew you to the Philadelphia area, if you are not from there? Attended college/grad school in Philadelphia, and always wanted to work and live here. Opportunity finally arose last year. Love being right in the city gave up the car, and mostly bike around the city. Where did you go to college at, grad school and were you a member of any groups, sports teams, etc. that might interest people? Graduated from University of Pennsylvania with BA and MA in Regional Science (urban and regional economics) after washing out of pre-med (but I finally did understand some physics after taking Location Theory). Perhaps most notable activity after a lot of cards, pinball and beer was running a coffee house, the Rat Cellar (not Rathskellar). Very active in alumni affairs class reunion planning, secretary of local alumni club, interviewing applicants for undergraduate admission. I run a Casserole Blitz twice a year in which a group of alums prepares casseroles for the University City Hospitality Coalition to feed dinner to homeless people. Active in other social impact programs, especially those which address homelessness (while living in Michigan, was on the board of an organization which operates a shelter for homeless families and supports them after they transition to their own housing) and hunger. How long have you been an Independent Public FA? Nearly 18 ½ years currently with First River Advisory, LLC. Do you have any hobbies or activities you enjoy that you would like to share? I love to watch old movies, especially post-war genre with social message or historical context. I love what I do, but I d rather help Robert Osborne introduce the movies on TCM. Other alternative career choices (especially if I get regulated out of business) include over-the-road trucker and partnering with a friend (who may get frustrated with his corporate law practice) to run a gourmet food truck on the Penn campus. Enjoy all sorts of live performances (so easy here in the city!), reading history books, especially baby-boom generation, and attending related author talks (most recently Jeff Greenfield and Robert Dallek, both on Kennedy). Any details about your family you would like to share? One son, age 25, a music therapist who performs with a symphony orchestra and a few choral groups on the side. He has all the musical talent I can play only the radio. It appears that a relative was a Mayor of Stockholm. Another ran a wellknown art gallery in NYC. When you were in school did you ever dream of one day having the job you have now? You gotta be kidding? The only thing that I knew about bonds back then was from that old Little Rascals episode in which the old lady gives the gang some bonds to use for a tail on their kite. She remarked that the man told her that those bonds would go up. 2

3 2013 NAIPFA Conference Wrap up The 2013 National Conference held October 9-11 in Nashville, TN, was well attended with about 130 participants. Nashville is a beautiful city with a rich history both in governance and country music, which provided a perfect backdrop for learning and fun. The challenge we've had in recent conferences, is focusing on what we thought might happen with MSRB and SEC actions. With the definition of Municipal Advisor(MA) now adopted by the MSRB in a 777 document just weeks before the conference, sessions were revised to interpret and guide members on what will now be required. The focus this year was educating members so that NAIPFA members pass the MA test with top scores. Defining what an MA is or isn't, understanding the distribution channels for bonds, managing debt for issuers more effectively by evaluating interest rates and savings through the call date versus the term of the bonds, discussions on factors that impact interest rates through an underwriter's lens, bond math, compliance programs for new regulations, new credit rating methodologies and municipalities in distress, a look at real examples of what can go wrong and the remedies impacting bonds. We thank all attendees, sponsors, the conference committee, the Board and our executive director for a successful conference. Next issue will summarize the evaluations and suggestions for next year's conference in Portland, Oregon, October If you'd like to be on the conference committee or have ideas for topics, please Terri Heaton at theaton@springsted.com Introduction to Regulation Important Dates for Important Actions The SEC s Municipal Advisor Registration rules have been published in the Federal Register with an effective date of January 13, Therefore, beginning on January 13, 2014, all Municipal Advisors will be required to keep and maintain certain books and records in accordance with Exchange Act Rule 15Ba1-8. In addition, on or before January 13, firms that keep books and records electronically will need to have in place policies and procedures that are designed to ensure that those electronic books and records are maintained and secured appropriately. Then, on July 1, 2014, the Municipal Advisor permanent registration process (to replace the temporary registrations which have been in effect since 2010) is scheduled to begin, and firms will begin having to register. MA firms must file permanent registrations by filing their Forms MA and a Form MA-I for each natural person who will be designated as a Municipal Advisor (i.e., employees and sole proprietors). These Forms will need to be filed utilizing the SEC s online database, EDGAR. However, before gaining full access to EDGAR and having the ability to file Forms MA and MA-I, firms will need to obtain EDGAR security codes. Firms obtain codes by filing an SEC Form ID with EDGAR. Once the security codes are obtained, firms will be able to access and submit their Forms. The deadline for each firm s registration depends upon the firm s temporary SEC (not MSRB) registration number. The following table sets forth the corresponding filing deadline for each series of temporary SEC registration numbers: Temporary Registration Registration Numbers Between: Ending Date to July 31, to August 31, to September 30, to October 31, Continued on Page 4.

4 Firms are permitted to begin registering on July 1, 2014, regardless of their temporary registration number. In such instances, the Forms will be held by the SEC and deemed filed as of the 1st day of the month in which a firm was required to register. In other words, if a firm is required to register during the period of August 1 through August 31, but the firm files if Forms on July 15, the SEC will deem the firm s Forms to have been filed on August 1. If your firm fails to register, its temporary registration will expire 45 days following its registration deadline. Thereafter, if the firm continues to engage in Municipal Advisory activities, the firm, and potentially its employees, will have committed securities law violations. Therefore, it is recommended that firms begin preparing for registration now by ensuring that appropriate policies and procedures are in place prior to January 13, 2014 to help ensure compliance, not only with the SEC s books and records requirements, but also with Municipal Advisor fiduciary duty and fair dealing obligations. In addition, firms should complete and file their Form ID sooner rather than later. Firms should also compile information on their employees in order to accurately complete a Form MA-I for each Municipal Advisor employee. With respect to the completion of Form MA-I, each firm will have to determine whether and to what extent to conduct due diligence into the information provided by each employee necessary to complete the Form MA-I for such employee. However, it is recommended that firms conduct some reasonable due diligence into any such information particularly with regard to any matters that are easily verifiable. Finally, if you have any questions about registration, the forms or compliance related matters, it is recommended that you contact your firm s compliance officer or legal counsel. NAIPFA President Salutes the SEC s Final Series of Muni Advisor Rules Bond Buyer Commentary October 25, 2013 Nearly three years after the Securities Exchange Commission released its proposed rules concerning the registration of municipal advisors, we now have a series of final rules that provide needed clarifications to the definition of the term municipal advisor. The National Association of Independent Public Finance Advisors supports the practical, common -sense approach taken by the SEC and its office of municipal securities and believes that these rules will directly benefit the interests of issuers by creating a more robust, fair, competitive and transparent municipal market. For too long there has been an ambiguity with respect to the roles played by various market par- ticipants in municipal securities transactions. The rules remedy this by establishing clear delineations, primarily with respect to municipal advisors, but also with respect to other market participants, such as broker-dealers, engineers, CPAs and attorneys. For example, the rules make it clear that individuals providing advice with respect to the structure, timing, terms and other similar matters will generally be considered to be municipal advisors, whereas persons who merely provide general information to issuers will not. The rules make sense as approved and provide needed protections to muni issuers by ensuring that they will receive unbiased advice from fiduciaries, with only limited exceptions. However, NAIPFA is troubled to hear that some municipal market participants, particularly those within the broker-dealer community, are engaged in a concerted effort to undo the rules issuer protections before they are even effective, undermining the very laws that they pushed so vigorously for in Among the arguments being put forth by some broker-dealer groups is that the rules will cut off or impede the free flow of ideas between broker-dealers and issuers. NAIPFA disagrees. Under these rules, broker-dealers are free to provide general information to issuers. In addition, the rules do not prevent broker-dealers from providing advice. They simply require broker-dealers to be engaged as underwriter prior to providing advice to an issuer. Therefore, we disagree with the notion that this rule will cut off or impede the flow of information....continued on Page 5 4 naipfa PO Box 304 Montgomery, IL Tel: Toll Free: Fax: rhoban@naipfa.com Check out our website: Burning Bright!

5 NAIPFA continues to be very engaged in the MA definition. We have submitted letters and commentaries over the past month that may be found on our website. We have been in frequent contact with the Securities and Exchange Commission as it explores ways to further clarify the MA definition. In addition, we will be traveling to Washington in January to attend the MSRB roundtable and to hold additional meetings with key regulators. We have and will continue to work very hard to ensure that the concerns of independent municipal advisors are being heard and that the interests of our member firms are being protected. Finally, our Board of Directors will be holding a Board Conference Call next week and our Spring Board Meeting will take place on February 28, I wish you all a joyous holiday season. Similarly, it is incorrect to suggest that if issuers do not receive particularized advice from a broker-dealer prior to their engagement as the issuer s underwriter that issues will not come to market. We must remember that it is the issuer, not the broker-dealer, who is to control whether, why and how to issue securities, which are determinations that must not be impermissibly influenced by broker-dealers whose interests diverge from those of issuers. Thus, whatever impact these rules may have on the free flow of information will be outweighed by the significant issuer protections that these rules put in place. However, we have in the past seen significant barriers within the muni market, but these barriers have primarily been to competition, not the free flow of information. For example, historically, many broker-dealers represented themselves as onestop-shops for all municipal securities matters. We are hopeful that these rules will break down these barriers by forcing broker-dealers to determine early on in transactions what role they intend to serve that of municipal advisor or underwriter. This is a significant improvement from the status quo that will improve competition and provide needed protection to municipal issuers, who may otherwise be led to believe that broker-dealers are acting in their best interest. We also understand that some broker-dealer groups are attempting to convince issuers, lawmakers and regulators that if they are not permitted to provide advice to issuers prior to their engagement as an underwriter, that issuers will be unable to identify refinancing opportunities. NAIPFA, again, disagrees. Municipal advisor firms, and NAIPFA member firms in particular, many of whom employ individuals who are certified independent public finance advisors, have and will continue to identify and provide advice to issuers with respect to refinancing opportunities. In addition, although some broker-dealers continue to state that financial advisors do not add value to a transaction, the SEC, the Government Finance Officers Association and others have pointed out in numerous releases that research has consistently shown that the use of municipal advisors can lower an issuer s borrowing costs. PRESIDENT S CORNER 5 Finally, although the rule leaves many questions unanswered, NAIPFA does not believe that there is any question as to the rules interplay with current Municipal Securities Rulemaking Board Rule G-23. Recently, the SEC reiterated that G-23 is a conflicts rule and stated that it is not superseded or otherwise invalidated by the passage of the rules. The rules work well within current Rule G-23 s framework insomuch as it prevents a broker-dealer from underwriting an issuer s securities where a financial advisory relationship exists. This fact, paired with the rules test for determining whether an individual is required to register as a muni advisor, leads NAIPFA to conclude that a broker-dealer who provides municipal advisory services to an issuer outside of an underwriting engagement will have developed a financial advisory relationship and will violate G-23 by underwriting that particular issuance of securities. In light of the foregoing, to the extent that litigation or legislative avenues are being considered by market participants as a means of preventing the implementation of the rules, NAIPFA reiterates what the SEC has stated previously that such actions will simply delay, perhaps by years, the regulation of municipal advisors and the implementation of these important issuer protections. Municipal market participants cannot continue to do business as they have in the past. It is time to adapt to the new normal and accept that the municipal market and its regulatory landscape have changed. NAIPFA and its member firms have waited nearly three years for the rules and are now awaiting the day when we can begin registering as municipal advisors, permanently. We also look forward to representing the interests of regulated municipal advisors and working with the MSRB as it promulgates municipal advisor rules. NAIPFA Open Letter to SEC Chairman Mary Joe White Dated November 22, 2013 To view the entire contents of the letter submitted on November 22, 2013, please visit our website at: naipfa.com/wp-content/uploads/2012/12/naipfa-open- Letter-to-SEC.pdf...Continued on Page 6

6 naipfa PO Box 304 Montgomery, IL Tel: Toll Free: Fax: Check out our website: Winter Wonderland Bond Buyer Article November 22, 2013 NAIPFA to SEC: MA Rule Won t Hurt Issuers By Kyle Glazier WASHINGTON - The National Association of Independent Public Finance Advisors has sent an open letter to Securities and Exchange Commission chairman Mary Jo White insisting the municipal advisor rule the SEC adopted in September will not restrict the flow of information between issu- ers and other parties to a bond deal. The NAIPFA letter comes a week after dealer firms were considering launching a media campaign to portray the rule as potentially disastrous for issuers. Penned by President Jeanine Rodgers Caruso, the NAIPFA letter reiterates the group's support for the rule as adopted unanimously by the SEC's five members. Copies of the letter also were sent to SEC muni chief John Cross and to Municipal Securities Rulemaking Board executive director Lynnette Kelly. Dealers have been arguing the final rule will restrict their ability to communicate with issuers the way they have for decades. Under the rule, giving particularized advice to a municipal entity would force a dealer firm to register as an MA and take on a fiduciary duty to put the issuer's interests ahead of its own. Dealers and regulators both consider a fiduciary duty to be inconsistent with the role of an underwriter, meaning that the common practice of sending unsolicited "pitches" to issuers might grind to a halt under the MA rule. The rule allows anyone to provide general information or objective facts to an issuer without incurring a fiduciary responsibility. "NAIPFA believes that the rules will help preserve the integrity of the municipal market by ensuring that issuers will receive needed protections, particularly with respect to the advice they receive in connection with the issuance of municipal securities and municipal financial products," Rodgers Caruso wrote. "NAIPFA disagrees with the notion that the rules will restrict issuer access to market information or that the rules will otherwise result in financing delays. Rather, the rules allow anyone to provide general information without having to register as a municipal advisor." The Bond Buyer reported about 10 days ago that the Securities Industry and Financial Markets Association had circulated a draft letter to its member firms entitled "An Open Letter to the U.S. Municipal Community," warning the SEC rule, slated to take effect in mid-january, would "restrict issuers' access to market information and impact their access to the capital markets - delaying financings for schools, hospitals, public housing, and other critical infrastructure projects in communities across America." The SIFMA draft urged issuers to express their concerns to federal regulators and members of Congress. SIF- MA declined to comment on the content of NAIPFA's letter, but Michael Decker, the group's manag- ing director and co-head of the municipal securities group, indicated more SEC guidance would be needed to allow for a healthy situation for issuers. "Absent more flexible guidance from the SEC, when the municipal advisor rule takes effect in January, issuers will be left to depend to an even greater extent on [financial advisors) that remain unregulated and not subject to testing or licensing. The municipal advisor provisions in the Dodd Frank Act are intended to protect issuers from unregulated, non-dealer financial advisors, not impede communications between issuers and their bankers." Rodgers Caruso's letter goes on to state that although the rule is certain to create some change for issuers by formalizing the way they receive advice from dealer firms, nothing in the rule should cause the quantity or quality of information issuers receive to decline. The letter points out that issuers could still receive generalized information from broker-dealers wishing to underwrite bonds, and could rely on exemptions that allow dealers to provide advice in response to issuer requests for proposals from multiple firms or if the issuer already retains its own municipal advisor. The letter also cites a recently released report from Missouri State Auditor Thomas Schweich, which concluded many local government officials are not equipped to negotiate the bond issuance process and that localities in the "Show Me State" could have saved millions between had they retained their own advisors. Although underwriters and municipal advisors may continue to disagree on this point," the NAIPFA letter states, "we are certain that the rules, as approved, will help protect issuers."...continued on Page 7 6

7 NAIPFA Summary Regarding IRS REG Arbitrage Restrictions on Tax-Exempt Bonds On September 13, 2013, the IRS released two sets of proposed regulations that would make several significant changes to, among other things, the way in which issue price is to be calculated. Currently, the determination of issue price is determined based upon the price at which a substantial amount of the securities are sold, where the term substantial amount is defined as 10% of the bonds. In addition, underwriters are currently permitted to rely on their reasonable expectations about sale prices at the time of pricing. However, the IRS s proposed changes would eliminate an underwriter s ability to rely on its reasonable expectations, and would change the definition of substantial amount to 25%. Thus, the issue price would be determined based solely upon an underwriter s ability to sell 25% of the securities. Further, because issue price must be based upon actual sales prices, and because it may not be possible to determine the issue price on the sale date, or even by the issue date, the proposed rules permit issuers to make yield reduction payments to the IRS if the issue prices are later determined to be higher, and the yield lower, than estimated. These changes are particularly concerning within the context of competitive sales. NAIPFA is concerned that these rules could have a significant negative financial impact on issuers, and could undermine the use of the competitive sale method all together as it is unlikely that underwriters would be able to meet this 25% threshold within the necessary time frame. This may result in issuer s having to make yield reduction payments due to underwriter cheapening of prices, which could also result in issuers receiving prices and yields that are less favorable than those proposed by other bidders. These results and the uncertainty created therefrom, could significantly curtail issuer, and underwriter, willingness to participate in competitive sales. As such, NAIPFA is in the process of drafting a comment letter to the IRS opposing these proposed rules. NAIPFA Strongly Supports Preservation of the Tax- Exemption of Municipal Bonds There remains a clear and present threat that the U.S. Congress could act to eliminate the tax-exempt status of municipal securities. NAIPFA remains vigilant while working with issuer and industry groups across the Country to support efforts to maintain the uncapped tax-exempt status of municipal securities. It was widely expected that the issue of taxexemption, as a part of comprehensive tax reform, would be considered concurrently with the next round of efforts to increase the U.S. debt ceiling, and it was not during the most re- 7 Many organizations have published white papers which clearly state that any benefit the U.S. government would receive through the elimination of tax-exemption of municipal securities would pale in comparison to the increased costs which would be experienced by state and local issuers of tax-exempt debt. The American Society of Civil Engineers projects that approximately $3.7 trillion in new debt financing will be needed to construct new and rehabilitate existing infrastructure by 2020, and that approximately 90 percent of the cost will be borne by state and local governments. NAIPFA strongly supports the efforts of all issuer organizations to preserve the tax-exemption of municipal securities. A Resource Providing Municipal Securities Industry Leadership NAIPFA has become the recognized leader in representing the positions and views of independent Municipal Advisors. NAIPFA is an active participant in the MSRB Municipal Securities Industry Roundtable which brings together representatives from the American Bankers Association, Bond Dealers of America, Government Finance Officers Association, Investment Company Institute, National Association of Bond Lawyers, National Association of State Auditors, Comptrollers and Treasurers, Securities Industry & Financial Markets Association, and National Federation of Municipal Analysts and others to discuss issues of concern to issuers, investors, and the public trust in the municipal securities industry, the next meeting of the MSRB Municipal Securities Roundtable will occur on January 10, NAIPFA members serve on the MSRB Professional Qualifications Advisory Committee ( PQAC ) and have been intimately involved in the process of developing an outline for municipal advisor examination and as members of the committee which is developing questions which will comprise the MA Examination. Securities and Exchange Commission Update The Securities and Exchange Commission has five Commissioners who are appointed by the President of the United States with the advice and consent of the Senate. Their terms last five years and are staggered so that one Commissioner's term ends on June 5 of each year. To ensure that the Commission remains nonpartisan, no more than three Commissioners may belong to the same political party. The President also designates one of the Commissioners as Chairman, the SEC's top executive. Mary Jo White was sworn in as the 31st Chair of the SEC on April 10, The remaining members of the Commission include Luis Aguilar, Daniel Gallagher, Kara Stein, and Michael Piwowar, the latter two confirmed to office just recently. NAIPFA wishes former Commissioner Elise Walter the best following her retirement from the Commission, and extends great appreciation for her personal willingness, and that of her staff, to be accessible and interested in the views and opinions of NAIPFA....Continued on Page 8

8 The SEC has implemented the process of on-site examination of independent MA firms and several firms have been examined to date. NAIPFA reminds all MA firms that SEC examinations are underway and that your firm should now be prepared for the examination process. Additionally, NAIPFA has made an offer to the SEC to assist with the development of Best Practices for independent MA SEC on-site examination. MSRB Rulemaking Update The MSRB has stated that once the Final MA Definition has been released, it expects to resubmit to the SEC certain rules which had previously been submitted and subsequently withdrawn, and submit a number of new rules. NAIPFA expresses gratitude to MSRB Chairman Daniel Heimowitz and Executive Director Lynnette Kelly for their participation in, and attendance of, the 2013 NAIPFA Annual Conference in Nashville. According to Chairman Heimowitz and Director Kelly "In the year ahead, the MSRB is focused on enhancing the integrity of the municipal market by improving pricing for investors and issuers and implementing a regulatory framework for municipal advisors." NAIPFA will continue to look to any opportunity to assist their efforts to protect the interests of investors, issuers, and the public trust. NAIPFA member firms should be aware that once the Final MA Definition is released, the MSRB will become very active in fulfilling its mandate to complete the regulatory structure for the MA Industry. NAIPFA member firms should be ready to implement changes to existing business processes and approaches necessary to comply fully with these new regulations. Additionally, now that the Final MA Definition has been released, NAIPFA expects for the process of testing to move forward and recommends for its members to prepare for the testing and certification process. A general recommendation is to begin by referencing the materials and sources NAIPFA recommends to prepare for CIPFA Exam. Additionally, it is anticipated that the MSRB will circulate materials prior to testing which will provide additional information regarding test preparation. NAIPFA Expresses Gratitude to the GFOA The NAIPFA Public Affairs Committee continues to be grateful to have the chance to work with Dustin McDonald with respect to a range of issues and topics concerning the municipal securities marketplace, with specific emphasis directed toward the impact of SEC and MSRB rules and actions affecting municipal issuers. NAIPFA was honored to have the benefit of Dustin s insights as guest contributor to the August Newsletter, and we once again express thanks and gratitude for his insightful contribution. NAIPFA will continue to align debt issuance and management policy interests with those of the GFOA to bolster support for legislative initiatives which expand issuer protections and enhance efficient access to the municipal marketplace. We look forward to continuing to work with Dustin and GFOA to create a more competitive and efficient marketplace for municipal issuers. The Future of NAIPFA, Tax-Exemption, Regulation, and Governmental Relations The future of the municipal securities industry is being actively debated in Washington D.C. today. All municipal industry participants are confronting public policy changes which are either historical or generational in nature. We urge all NAIPFA members to become involved and make contact with their U.S. Representatives and Senators, or staff members dedicated to the House Ways and Means Committee and Senate Finance Committee to discuss the importance of maintaining tax-exemption for municipal securities. The NAIPFA Public Affairs Committee Members are Jeanine Rodgers Caruso, NAIPFA President; Steve Apfelbacher, President, Ehlers Inc.; Tom Johnsen, Partner, Fieldman Rolapp & Associates; John Haas, President of Ranson Financial; Shelley Aronson; President of First River Advisory; Nate Howard, NAIPFA Legal Counsel; and Chairman Larry Kidwell. NAIPFA has issued testimony, commentary, official letters, responses, position statements and editorials, and has collaborated with other municipal securities industry organizations to co-author other public policy position releases. Responding to NAIPFA Member requests, the Public Affairs Committee has undertaken to provide notice and content of publicly released information to the NAIPFA Membership utilizing ListServ prior to the release of such information to the public. All NAIPFA information released to the public is available for view and download at It has been a busy two months since our Annual Conference in Nashville for the Public Affairs Committee, and we expect it will be a lot busier in the coming months and we will do our best to keep the NAIPFA membership well represented and informed. Wishing You A Warm & Happy Holiday Season! 8