MSRB Tweaks Rules on Municipal Offering Structuring Exclusions
Published Date: 8/4/2026
Notice
Summary
No summary available.
Analyzed Economic Effects
4 provisions identified: 2 benefits, 1 costs, 1 mixed.
Firms must adopt final-approval policies
Dealers would be required to adopt compliance policies and procedures that define what action constitutes the dealer's final approval of a public offering or private placement transaction, and the MSRB states final approval should be conducted by a person in a principal-level capacity (i.e., a municipal securities principal). These policies must consider relevant factors and support evidencing compliance to examiners.
Estimated firm compliance costs and savings
The MSRB estimates one-time upfront costs to dealers of about $3,446 per firm (policy revisions, counsel review, approvals, and training) and ongoing annual costs of about $2,440 per firm for compliance review tied to the proposed changes. The MSRB also states dealers could see reduced expenses for inspecting, licensing, and supervising OMSJs if some locations no longer require OMSJ designation.
Certain public finance tasks excluded
The MSRB would add rules saying some public finance activities—such as debt modeling, financial analysis, number running, and soliciting issuers for public finance banking services—are “excluded public finance activities” and would not by themselves count as the “structuring of public offerings or private placements.” Final approval of a public offering or private placement (i.e., the dealer's internal final approval) is explicitly NOT excluded and still counts as structuring that must be done at an OMSJ.
Work-from-residence days increased to 90
The MSRB would change the municipal branch office rule so that an associated person may work at a non-primary residence for up to 90 business days per calendar year (instead of the current less than 30 business days) without triggering municipal branch office designation, provided the existing conditions in Rule G-27(g)(ii)(A)(2)(a)-(h) are met. The conditions for the exclusion remain unchanged.
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