The MSRB provided answers to frequently asked questions ("FAQs") on the continuing education requirements for municipal advisors under MSRB Rule G-3 (see previous coverage).
The FAQs included the following:
- Municipal advisors will have until December 31, 2018 to conduct a needs analysis and develop a written training plan;
- Municipal advisors must provide training on fiduciary duty obligations owed to municipal entities regardless of whether they have municipal entities as clients;
- There is no minimum hour requirement for a continuing education program;
- Sole proprietors have considerable flexibility in implementing continuing education requirements, including the option to utilize existing content to save costs;
- All covered persons must participate in the continuing education program;
- Firms may disseminate materials to covered persons from a webinar attended by one such covered person;
- There is no specific type of training required for municipal advisor principals; rather, a firm may determine that training in specific areas is needed and appropriate based on its needs analysis;
- Municipal advisors may use vendors to administer continuing educations programs, although municipal advisors retain responsibility for full compliance;
- Dealer-municipal advisors must conduct separate needs analyses for their municipal advisory activities and dealer activities;
- Municipal advisors must maintain evidence that covered persons completed training programs; and
- Municipal advisors must document the content of their training programs.
The FAQs also contain additional resources and materials that support compliance with continuing education requirements.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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