Stay On Municipal Advisor Rules Expires July 1, 2014

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 also define this statutory term and provide certain exclusions and exemptions from the registration requirement.

Under the SEC's final rules, a municipal advisor is generally defined as a person who:

• provides advice to a "municipal entity" (i.e., any state, political subdivision of a state or municipal corporate instrumentality of a state or political subdivision) or an "obligated person" (i.e., any person who is committed by contract or other arrangement to support the payment of all or