in many cases can result in higher costs andor the shutting out of the issuer ID: 824402
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reconsidered in the context of this new
reconsidered in the context of this new comprehensive MA regulatory structure.1 !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!""Note that even the Broker-Dealer Guide on the Division of Trading and MarketÕs website predates the Dodd-Frank Act and the development of the municipal advisor regulatory regime. in many cases can result in higher costs and/or the shutting out of the issuerÕs fiduciary during stages of the transaction where the issuer ese t
ypes of market a significant amount of
ypes of market a significant amount of analysis and regulatory activity on the part of the SEC (whether through rulemaking, interpretive guidance or exemptive actions), we stand ready to work closely with the SEC and other market constituencies to craft the appropriate measures to achieve such parity. We, however, do not believe that a solution to address the specific problem arising from the regulatory confusion around direct placementsSee, e.g., Exchange Act R
elease No. 70462 (September 20, 2013) at
elease No. 70462 (September 20, 2013) at text accompanying footnote 34 for the SECÕs acknowledgment of MAÕs historic role in assisting their clients to Ònegotiate the financing termsÓ and text preceding footnote 556 regarding the role of MAs in assisting their municipal policies and procedures for their transactions. Our members have facedbased exemptions. Our municipal advisor members are committed to serving their clients effectively and faithfully to fulf