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Exclusions/Exemptions
Retention Period
"Qualifies as" - All questions will include the phrase "Qualifies as"
100
A document that identifies a particular objective for which ideas are being solicited, that is open for a finite period, and is distributed to at least three competitive parties.
What is an RFP/RFQ and is required evidence for the RFP/RFQ exemption?
100
3 years
What is the retention period under SEC 17a-4 for: • Originals or copies of all written communications received, and sent; • Check books, bank statements, general ledgers, cancelled checks, and cash reconciliations; and • Records of the names of persons who are, or have been associated with firm.
100
Emails, snail mail, instant messaging
What qualifies as written communication?
200
A letter that affirmatively demonstrates the selection of a broker-dealer for a particular issuance of securities.
What is evidence for underwriting exemption?
200
2 years
What is the time period that MA firms must retain books and records in an easily accessible place?
200
Check books, bank statements, credit card statements, cancelled checks, cash reconciliations
What is qualifies as records for financial statements?
300
Written representation from the municipal entity that it has representation and will rely on the advice.
What is evidence for the Independent Registered Municipal Advisor (IRMA) exemption?
300
5 years
What is retention period under MSRB rule G-8(h)and SEC 15Ba1-8 retention period?
300
Anticipated cash flows, Issuer needs, Issuer credit worthiness, (add more)
What qualifies as basis for recommendations?
400
An investment advisory agreement
What documents the advice that is excluded from the municipal advisor definition pursuant to the registered investment advisor exclusion?
400
6 years
What is the retention period following a change in designation for a person under G-8(h)?
400
Factual information or general market color, delivered objectively
What qualifies as general information?
500
Documentation displaying only basic Introduction and Overview, or factual information which does not express subjective views
What is evidence of General information exclusion?
500
Indefinite
What is the retention period for a legal hold?
500
Issuer-specific information delivered to support a recommendation
What qualifies as advice?