Do firms whose only municipal securities business is limited to the sale of municipal fund securities need to comply with SEC Rule 17f-2, the fingerprinting rule?
Yes. Rule 17f-2 requires, among other things, that broker-dealers require each of their “partners, directors, officers, and employees” to be fingerprinted. The rule exempts from the fingerprinting requirements broker-dealers that are “engaged exclusively in the sale of shares of registered open-end management investment companies, variable contracts, or interests in limited partnerships, unit investment trusts or real estate investment trusts” 17f-2(a)(1)(iii)(A). However, municipal fund securities are municipal securities, and the rule does not provide an exemption for such securities.
Related Questions
- Do firms whose only municipal securities business is limited to the sale of municipal fund securities need to comply with SEC Rule 17f-2, the fingerprinting rule?
- Are Municipal Fund Securities subject to the requirements of SEC Rule 15c2-12 (municipal securities disclosure)?
- Are firms that sell Municipal Fund Securities subject to the rules of the MSRB?
