Chrys A. Carey

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Firm/Organization: Morrison & Foerster LLP
Blogs: The BD/IA Regulator

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The SEC is not wasting any time making sure that newly registered municipal advisors are introduced to their regulator.  On August 19, 2014, the SEC announced a two-year examination initiative for municipal advisors that registered with the SEC in accordance with final municipal advisor rules that became effective on July 1, 2014.  OCIE’s National Examination Program (NEP) stated that the initiative will include “focused, risk-based” examinations of municipal advisors registered with the SEC but not…
The U.S. House of Representatives on June 24, 2014, passed a version of the CFTC reauthorization bill, H.R. 4413, that would exclude investment advisers to registered investment companies (RICs) from the definitions of commodity pool operator (CPO) and commodity trading advisor (CTA) if they limit their advice and trading activity to “financial commodity interests.” H.R. 4413 (the Customer Protection and End User Relief Act) included an amendment introduced by Representative Garrett of New Jersey.  The…
The temporary stay previously imposed on the SEC’s final municipal advisor rules expires July 1, 2014.  Accordingly, municipal advisors will be required to register with the SEC on Form MA on a phased-in schedule beginning July 1, 2014, and ending October 31, 2014. Registration of “municipal advisors” under Section 15B of the Exchange Act was mandated by Section 975 of the Dodd-Frank Act.  The SEC’s final municipal advisor rules not only impose registration requirements, but…