Institute Comments on Proposed Amendments to MSRB Qualification Requirements

Washington, DC, January 15, 2002 - The Institute filed a comment letter with the Municipal Securities Rulemaking Board (MSRB) regarding proposed amendments to Rule G-3, relating to qualification requirements, that would create a new category of municipal securities principal, a municipal fund securities limited principal (MFSLP). As proposed, a person with either a Series 24 or 26 principal registration could qualify as a MFSLP by passing a new examination limited to questions that are relevant to municipal fund securities activities. Passage of this new examination would qualify a person to supervise a firm's municipal fund securities activities without having to pass the municipal securities principal examination (Series 53), which is geared toward traditional municipal securities activities.

The Institute's letter supports the creation of this new principal category, which will provide needed relief to those firms whose municipal securities business is limited to municipal fund securities.

The Institute's letter also notes the temporary relief provided by the MSRB in July 2001 to certain general securities or investment company/variable contracts limited principals that permits them to serve as municipal securities principals. In view of the fact that this temporary relief is set to expire on July 31, 2002, the Institute's comment letter requests that the temporary relief be extended until the new MFSLP examination is ready to be administered. Otherwise, persons who would prefer to qualify as a MFSLP will, instead have to qualify as a municipal securities principal.