SEC Extends Temporary Registration Of Municipal Advisors

On December 21, 2011, the Securities and Exchange Commission (the "SEC") extended the term of the interim final temporary rule providing for the temporary registration of municipal advisors (the "Interim Rule") to September 30, 2012. The Interim Rule had been scheduled to expire on December 31, 2011, and other rules proposed by the SEC in December 2010 that had provided guidance for, and definitions of, terms relating to the municipal advisor registration scheme had also been expected to be finalized by the end of December 2011. Given the extension of the Interim Rule, it is now expected that the SEC may adopt permanent rules defining the contours of municipal advisor registration in the second half of 2012. As discussed in greater detail below, the municipal advisor registration regime may have significant implications for investment advisers and broker-dealers, though the current state of the rulemaking leaves open several interpretive questions.