We are asking each member firm and their employees to please forward a version of the letters below (in a Word Document) to their local Congressional leaders. Please customize this letter to your specific firm. There is one letter for the House of Representatives (House of Rep Letter) and one for the Senate (Senate Letter). Please send both. We need numbers here.
To find your local representatives:
· House of Representatives: http://www.house.gov/representatives/
Find your representative by entering your zip code. Please do this for work and home zip codes.
· Senate: http://www.senate.gov/
Find your senators by entering State. Please do this for work and home states if different.
You can then go to their webpages and there is a place you can email each. The best way to do this is to cut and paste the cover letter and the Key arguments into this the submission form and then send. You can always send the full letter as a follow-up. What I suggest is submitting the letter electronically and then send a hard copy to your Congressperson at their local addresses. You can then attach the full letter so they have it for reference. This is what I did.
Please note that the senators won’t differ by State, but for those of you who live and work in different location, please feel free to submit to the Senators in each State. Representatives work a bit differently so chances are most people have different Representatives for work and home. Again, please send the letter to the appropriate Representatives in both locations. It would also be helpful to circulate this letter to the staff in your firm so they can do the same. The more Congressmen we hit where people are constituents the better it will be for our effort.
Feel free to forward the letter and this information on to anyone you think might support our efforts. If you know someone in the press that might be interested, please touch base with the 3PM office first so they can check with the PR team to ensure we are not duplicating efforts. Feel free to send to any investors as well that you think might support our position.
Should you get a response and want to involve one of us in the call with you, please feel free to contact me and either I, Lisa Roth or a member of the Board will work with you on a response or even join you on a call if you would like. When talking to Congress please remember to include the following points:
· THE MSRB and SEC are misguided in their development of MA rules.
· 3PMS are highly regulated as BDs and/or SEC or State IA’s. (high barrier to entry, ongoing high cost of compliance, net capital requirements, routine regulatory audits)
· Even when/if the full rule set is implemented, MA’s will have only the rudimentary application process possibly a license or two, no audit, no meaningful compliance.
· By putting 3PMs and MAs in the same ‘bucket’ the MSRB and SEC are creating a substantial loophole through which MAs will be able to conduct themselves as placement agents (unregistered broker-dealers).
· Firms can work as a Placement Agent with little to no understanding of the industry and no specific rules to keep them in check which can leave Municipal Investors open to injury
· MSRB and SEC are dismantling a barrier that is an important component of industry regulation.
· MSRB and SEC MUST differentiate between MAs with no other regulatory oversight and MAs that are also subject to FINRA’s oversight in their rule making.
We welcome your feedback and any assistance you can provide with these efforts.
Click here to read the full MSRB SEC Letter
Click here to download the House of Rep Letter
Click here to download the Senate Letter
Join the discussion on our LinkedIn!