Upcoming Municipal Advisor Temporary Registration Deadline

The U.S. Securities and Exchange Commission (the "SEC") recently adopted a Final Rule to establish a permanent registration regime for Municipal Advisors as required to implement the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). The Dodd-Frank Act prohibits municipal advisors from soliciting or providing certain advice to municipal entities (which are defined to include both state and local government entities) without first registering with the SEC. The Final Rule requires municipal advisors to make a temporary registration filing by January 13, 2014, to be followed by a permanent registration filing later this year.

The Final Rule has raised a number of interpretive issues. Industry groups have requested that the SEC provide some guidance in the form of a "No-Action Letter" or an FAQ. Additionally, on January 2, 2014, the Investment Adviser Association and the Securities Industry and Financial