MSRB WEBINAR Municipal Securities Dealers Continuing Education Requirements Hosted by the Municipal Securities Rulemaking Board December 4, 2014
Today s Webinar Topics I. About the MSRB II. Overview of Existing Key Provisions of MSRB Rule G-3 for Dealers III. Summary of Amendments to MSRB Rule G-3 for Dealers 2
About the MSRB
About the MSRB A self-regulatory organization created by Congress in 1975 Protects investors, municipal entities including issuers of municipal securities, obligated persons and the public interest Promotes a fair, transparent and efficient municipal market 4
Overview of Existing Key Provisions of MSRB Rule G-3 for Dealers
Current Continuing Education Requirements for Dealers Prior to the rule amendments, MSRB Rule G-3 defined covered registered persons as any person registered with a dealer who has direct contact with customers in the conduct of the dealer's securities sales, trading and investment banking activities, and to the immediate supervisors of such persons Also, MSRB Rule G-3 requires a two-part continuing education requirement for registered persons Regulatory Element; and Firm Element 6
Current Continuing Education Requirements for Dealers (continued) Regulatory Element Consists of periodic broadly applicable computer-based training on regulatory, compliance, ethical and supervisory subjects and sales practice standards Regulatory Element training must be successfully completed within a 120-day period that commences upon the second anniversary of the registered persons initial registration, and reoccurs every three years thereafter for as long as they remain in the securities business Firm Element Dealers are required to establish a formal training program to keep covered registered persons up-to-date on job-related and productrelated subjects 7
Current Continuing Education Requirements for Dealers (continued) Dealer training needs must be evaluated and prioritized at least annually Firm Element must be administered in accordance with dealer s annual needs analysis and written training plan Written training plan must be developed in response to needs analysis Consider dealer s size, structure, scope of business and regulatory concerns Maintain records documenting Firm Element program content and completion date 8
Summary of Amendments to MSRB Rule G-3 for Dealers
Amendments to Firm Element Continuing Education for Dealers Annual municipal securities training required for registered persons who regularly engage in and registered principals who regularly supervise, municipal securities activities Expanded definition of covered registered persons to registered persons who engage in a variety of municipal securities activities Ensures delivery of municipal securities training to those individuals active in the municipal securities market MSRB Rule G-3 aligns more with certain aspects of FINRA s continuing education requirements 10
Amendments to Firm Element Continuing Education for Dealers (continued) Dealers have flexibility to determine which municipal securities professionals are regularly engaged in and supervising municipal securities activities Persons regularly engaged in municipal securities activities, could include registered representatives: Engaged in the sale of municipal securities to customers and deriving more than a certain percent of their gross sales in the preceding year from municipal securities activities; Participating in a threshold level of municipal securities trades; or Part of a particular group within the dealer s firm (e.g., public finance group) 11
Amendments to Firm Element Continuing Education for Dealers (continued) Dealer should determine and document in its annual written training plan who should be trained Dealer should determine the nature of the training and training content based on the specific type of municipal securities activities conducted by the firm 12
Implementation Timeline SEC Approved Amended MSRB Rule G-3 October 15, 2014 Amended MSRB Rule G-3 Becomes Effective January 1, 2015 Completion of Required Annual Training December 31, 2015 (each year thereafter) 13
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MSRB WEBINAR Municipal Securities Dealers Continuing Education Requirements Hosted by the Municipal Securities Rulemaking Board December 4, 2014