ASA Submits Comments to MSRB on Municipal Advisor Rule Modernization

WASHINGTON – The American Securities Association (ASA) submitted a comment letter to the Municipal Securities Rulemaking Board (MSRB) in response to Notice 2026-03, supporting its proposed terminology modernization.

"Updating old terminology and taking a hard look at how these rules fit together is exactly the kind of housekeeping this rulebook needs," said ASA Chief Legal Officer Jessica Giroux. "We urge the MSRB to continue evaluating its rulebook and processes with an eye toward bringing them in line with how the industry functions today."

ASA's letter offered conditional support for the terminology modernization and outlined several key recommendations for the MSRB:



• Support the retirement of "financial advisor" terminology across Rules G-1, G-3, G-20, G-23, and G-37, conditioned on the MSRB concurrently updating all guidance documents that reference the retiring terminology to avoid replacing one form of ambiguity with another

• Support a Retrospective Review as a comprehensive cross-regulator undertaking that explicitly maps where MSRB rules overlap with or conflict with SEC and FINRA requirements, and eliminate or streamline duplicative obligations without regulatory purpose

• Provide clear role-based guidance for dually-registered personnel who face persistent ambiguity about which set of obligations governs which activity

• Treat the Core Duties phase as the analytical centerpiece of the review, allocating sufficient time to resolve the long-standing interaction between MSRB conduct rules and the SEC's fiduciary duty framework under Section 15B(c)(1)

To read ASA’s full letter to the MSRB, click here.

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The American Securities Association (ASA) represents the retail and institutional capital markets interests of regional financial services firms who provide Main Street businesses with access to capital and advise hardworking Americans how to create and preserve wealth. ASA’s mission is to promote trust and confidence among investors, facilitate capital formation, and support efficient and competitively balanced capital markets. This mission advances financial independence, stimulates job creation, and increases prosperity. The ASA has a geographically diverse membership of almost one hundred members that spans the Heartland, Southwest, Southeast, Atlantic, and Pacific Northwest regions of the United States.