BMA this week urged the SEC to approve proposed changes to MSRB Rule G-27 intended to provide greater flexibility for remote work for traders and bankers. BMA told the Commission “BMA fully supports the Proposal. We commend the MSRB for its leadership and innovation in addressing limited issues around Rule G-27.”
The MSRB has proposed to amend Rule G-27 in two ways. First, the proposal would extend from 30 to 90 days the time a supervised employee may work during the year from a remote location other than a primary residence. Second, the proposal would define “structuring” in the context of G-27 to include only “final approval of a public offering or private placement transaction (i.e., structuring) conducted by the dealer.” Activities such as “debt modeling, financial analysis, number running, and the solicitation of issuers or obligated persons for the dealer’s investment banking services in connection with municipal securities (e.g., public finance banking services)” would be excluded from the definition.
Both the MSRB and FINRA have indicated that they are contemplating more comprehensive reforms to their supervision regimes designed to provide even more flexibility for remote work. This summer FINRA held at least two industry roundtables on the topic. The MSRB has suggested that they are waiting for FINRA to solidify its proposal before moving forward with a more comprehensive plan.
We expect the SEC to approve the MSRB’s proposal. BMA’s letter to the SEC is available here. Please call or write if you have any questions.