One of my favorite clients just reprimanded me for not updating my blog to correctly identify our NH weather as SUNNY. Which it is. Thanks so much, Mr. Get Back to Work...
Oh, and I just talked to a gentleman at FINRA who was happy I wasn't a reporter when I asked about a rule interp. ?? Are they bombarded these days by the Geraldos of the world who aren't busily churning M.J. rumors? Guess so.
His answer to my question was that, yes, BD's who do nothing but 529 plans--that is, they sell municipal FUND securities, not municipal securities--are required to comply with interpretive material on G-17 about material event disclosures. See Notice 09-35 at http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p119067.pdf .
This means that before having your customer sign onto that 529 plan, make sure you visit MSRB's new EMMA site at http://emma.msrb.org/ to gather and convey important disclosures about the issuer. Document that you did this; and you supervisors: check the records to make sure it's being done. Oh, and update your procedures for this new one.
I dunno. I'm a bit skeptical. I have a call into MSRB. I hope they call back before it starts raining again...
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