Supporting Statement A

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PAPERWORK REDUCTION ACT SUPPORTING STATEMENT
for the Extension of
Rules 15Ba1-1 to 15Ba1-8 - Registration of Municipal Advisors and
Forms MA, MA-I, MA-W, and MA-NR
OMB Control Number 3235-0681
The U.S. Securities and Exchange Commission (“Commission” or “SEC”) submits this
information collection request (“ICR”) pursuant to the Paperwork Reduction Act of 1995, 44 U.S.C.
Section 3501 et seq. (“PRA”), with the following justification.

1.

Necessity of Information Collection

In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”)
amended Section 15B of the Securities Exchange Act of 1934 (“Exchange Act”) to require a new class
of regulated persons, “municipal advisors,” to register with the Commission.1 Section 15B(a)(1)(B) of
the Exchange Act, as added by the Dodd-Frank Act, makes it unlawful for a municipal advisor to
provide advice to or on behalf of a municipal entity or obligated person with respect to municipal
financial products or the issuance of municipal securities, or to undertake certain solicitations of a
municipal entity or obligated person, unless the municipal advisor is registered with the Commission. 2
On September 20, 2013, the Commission adopted Rules 15Ba1-1 through 15Ba1-8 3 and Rule
15Bc4-1 4 under the Exchange Act to establish the rules by which a municipal advisor must obtain,
maintain, and terminate its registration with the Commission. 5 The rules, among other things: (i) require
municipal advisors to file Forms MA, MA-I, MA-W, and MA-NR with the Commission to obtain,
maintain, or terminate their registration with the Commission,6 (ii) require municipal advisors to maintain
certain books and records in accordance with the Exchange Act, (iii) interpret the definition of the term

1

See 15 U.S.C. 78o-4;.Dodd-Frank Act, Pub. L. 111-203, title IX, section 975, July 21, 2010, 124 Stat. 1915 -1923,
available at https://www.govinfo.gov/content/pkg/PLAW-111publ203/pdf/PLAW-111publ203.pdf.

2

See 15 U.S.C. 78o-4(a)(1)(B).

3

See 17 CFR 240.15Ba1-1 to 17 CFR 240.15Ba1-8.

4

See 17 CFR 240.15Bc4-1.

5

See Registration of Municipal Advisors, Exchange Act Release No. 70462 (Sept. 20, 2013), 78 FR 67468 (Nov. 12,
2013) (“Final MA Rule Adopting Release”). The Office of Management and Budget (“OMB”) control number is 3235 0681.

6

See 17 CFR 249.1300 (Form MA), 17 CFR 249.1310 (Form MA-I), 17 CFR 249.1320 (Form MA-W), and 17 CFR
249.1330 (Form MA-NR). Reference copies of the forms and instructions are available at
https://www.sec.gov/files/formma.pdf (Form MA), https://www.sec.gov/files/formma -i.pdf (Form MA-I),
https://www.sec.gov/files/formma-w.pdf (Form MA-W), https://www.sec.gov/files/formma-nr.pdf (Form MA-NR),
and https://www.sec.gov/files/formmadata.pdf (Instructions for the Form MA Series).

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“municipal advisor,” (iv) interpret the statutory exclusions from that definition, and (v) provide certain
additional regulatory exemptions. 7 The rules became effective on January 13, 2014; however, on January
13, 2014, the Commission temporarily stayed such rules until July 1, 2014.8 Amendments to Form MA
and Form MA-I designed to eliminate aspects of the forms that request filers to provide certain forms of
personally identifiable information (“PII”) of natural persons, including Social Security numbers
(“SSNs”), dates of birth, and foreign identity numbers became effective on May 14, 2018.9
Rule 15Ba1-2 requires each person applying for registration with the Commission as a municipal
advisor to file electronically with the Commission Form MA and, with respect to each natural person
associated with the municipal advisory firm who engages in municipal advisory activities on its behalf ,
Form MA-I.10
Rule 15Ba1-4 requires that notice of withdrawal from registration as a municipal advisor be filed
electronically with the Commission on Form MA-W.11
Rule 15Ba1-5 and the Instructions for the Form MA Series require municipal advisors to amend
Form MA annually; amend Form MA whenever certain information previously provided therein
becomes inaccurate or materially inaccurate; amend Form MA-I whenever the information previously
provided therein becomes inaccurate for any reason; and amend Form MA-I to indicate that an
individual is no longer an associated person of the municipal advisory firm filing the form or no longer
engaged in municipal advisory activities on its behalf. 12
Rule 15Ba1-6 provides that each non-resident municipal advisor shall, at the time of its
application, furnish to the Commission for itself and for each non-resident general partner, non-resident
managing agent, and non-resident natural person associated with the municipal advisor who engages in
municipal advisory activities on behalf of the municipal advisor Form MA-NR, which appoints an agent
in the United States for the service of process, as well as an opinion of counsel on Form MA stating that
the municipal advisor can, as a matter of law, provide the Commission with access to its books and
records as required by law and submit to inspection and examination by the Commission. 13
Rule 15Ba1-7 requires municipal advisors to report succession of registration on Form MA. 14

7

See Final MA Rule Adopting Release, 78 FR 67468.

8

See Registration of Municipal Advisors; Temporary Stay of Final Rule, Exchange Act Release No. 71288 (Jan. 13,
2014), 79 FR 2777 (Jan. 16, 2014).

9

See Amendments to Forms and Schedules to Remove Provision of Certain Personally Identifiable Information ,
Exchange Act Release No. 83097 (Apr. 24, 2018), 83 FR 22190 (May 14, 2018).

10

See 17 CFR 240.15Ba1-2. The terms “municipal advisor” and “municipal advisory firm” are used interchangeably
herein. Both terms include sole proprietors. See Instructions for the Form MA Series, at 19, available at
https://www.sec.gov/files/formmadata.pdf.

11

See 17 CFR 240.15Ba1-4.

12

See 17 CFR 240.15Ba1-5; Instructions for the Form MA Series, at 2-3 & 4-5, available at
https://www.sec.gov/files/formmadata.pdf.

13

See 17 CFR 240.15Ba1-6.

14

See 17 CFR 240.15Ba1-7.

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Rule 15Ba1-8 and Form MA-I require each municipal advisory firm to obtain and retain, for not
less than five years, a written consent from each natural person associated with the municipal advisor
who engages in municipal advisory activities on its behalf that service of any civil action brought by, or
notice of any proceeding before, the SEC or any self -regulatory organization (“SRO”) in connection
with the individual’s municipal advisory activities may be given by registered or certified mail to the
individual’s address given in Item 1 of Form MA-I.15
Rule 15Ba1-8 requires all registered municipal advisors to maintain, for not less than five years,
true, accurate, and current books and records relating to their municipal advisory activities. 16
Rule 15Ba1-1(d)(3)(vi) exempts from the definition of “municipal advisor” any person engaging
in municipal advisory activities in a circumstance in which a municipal entity or obligated person is
otherwise represented by an independent registered municipal advisor with respect to the s ame aspects
of a municipal financial product or an issuance of municipal securities, provided that certain written
requirements are satisfied.17
Section 15B of the Exchange Act provides in pertinent part that, unless registered with the
Commission, a municipal advisor may not provide advice to or on behalf of a municipal entity or obligated
person with respect to “municipal financial products,” a term that is defined to include “investment
strategies” such as: (i) the recommendation of and brokerage of “municipal escrow investments,” and (ii)
plans or programs for the investment of the “proceeds of municipal securities.” 18
Rule 15Ba1-1(h)(2) provides that in determining whether or not funds to be invested or
reinvested constitute “municipal escrow investments,” a person may rely on representations in writing
made by a knowledgeable official of the municipal entity or obligated person whose funds are to be
invested or reinvested regarding the nature of such investments, provided that the person seeking to rely
on such representations has a reasonable basis for such reliance. 19
Rule 15Ba1-1(m)(3) provides that in determining whether or not funds to be invested constitute
“proceeds of municipal securities,” a person may rely on representations in writing made by a
knowledgeable official of the municipal entity or obligated person whose funds are to be invested
regarding the nature of such funds, provided that the person seeking to rely on such representations has a
reasonable basis for such reliance. 20

15

See 17 CFR 240.15Ba1-8(a)(8); Form MA-I, Item 7, available at https://www.sec.gov/files/formma -i.pdf.

16

See 17 CFR 240.15Ba1-8.

17

See 17 CFR 240.15Ba1-1(d)(3)(vi).

18

See 15 U.S.C. 78o-4(a)(1)(B), (e)(3), (e)(5).

19

See 17 CFR 240.15Ba1-1(h)(2).

20

See 17 CFR 240.15Ba1-1(m)(3).

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2.

Purpose and Use of Information Collection

Form MA and Form MA-I help ensure that the Commission can make information about
municipal advisors transparent and easily accessible to the investing public, including municipal entities
and obligated persons who engage municipal advisors; investors who m ay purchase securities from
offerings in which municipal advisors participated; and other regulators. Further, the information
provided on Form MA and Form MA-I expands the amount of publicly available information about
municipal advisors and their associated persons, including conflicts of interest and disciplinary history.
Although much of the information required by Form MA is already publicly available with respect to
municipal advisors that are already registered with the Commission as investment adv isers or brokerdealers, many municipal advisors that are not currently registered with the Commission in another
capacity will make this information available for the first time. Consequently, the rules and forms allow
municipal entities and obligated persons, as well as others, to become more fully informed about
municipal advisors in a more efficient manner.
In addition, the requirement that each municipal advisory firm register with the Commission on
Form MA and complete Form MA-I with respect to each natural person who is a person associated with
the municipal advisor and engages in municipal advisory activities on its behalf will help ensure that the
Commission has information to oversee respondents and their activities in the municipal securities
market effectively. In particular, the information provided in Form MA will be used to determine
whether to grant a municipal advisor’s application for registration or to institute proceedings to
determine whether registration should be denied. The information will also be used to focus
examinations and aid in risk-based examinations. Moreover, Form MA and Form MA-I will enable the
Commission to obtain an accurate estimate of the number of municipal advisors, by size and by
municipal advisory activity; analyze data regarding the various types of municipal advisory activities;
and evaluate the disciplinary history of all municipal advisors and associated persons, including
regulatory, civil, and criminal proceedings.
The requirement that a municipal advisor file amendments to Form MA and Form MA -I will
help ensure the availability of up-to-date information about municipal advisors and their associated
persons. In addition, the requirement that a municipal advisor file Form MA-W to withdraw from
registration will inform the Commission that a municipal advisor is no longer engaging in municipal
advisory activities.
The requirement that a municipal advisor make and keep books and records, including written
communications and records of associated persons, will help to ensure that records of the respondent’s
primary municipal advisory activities, as well as the activities of its associated persons, exist. The
Commission and other regulators could potentially request books and records during an examination to
evaluate the municipal advisor’s compliance with the Exchange Act, the rules thereunder, and Municipal
Securities Rulemaking Board (“MSRB”) rules, as well as for other regulatory purposes.
The requirement that a non-resident municipal advisor complete Form MA-NR, and furnish
Form MA-NR for its non-resident general partners, non-resident managing agents, and associated
persons engaged in municipal advisory activities, will help minimize legal or logistical obstacles that the
Commission may encounter when attempting to effect service, conserve Commission resources, and
avoid potential conflicts of law. The requirement that a non-resident municipal advisor provide an
opinion of counsel on Form MA will help ensure that such non-resident municipal advisor can provide
access to its books and records and submit to inspection and examination by the Commission.
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Similarly, the requirement that a municipal advisor obtain and retain a consent to service of
process from certain associated persons will help minimize legal or logistical obstacles that the
Commission and SROs may encounter when attempting to effect service, conserve Commission and
SRO resources, and avoid potential conflicts of law. The associated recordkeeping requirement will
help ensure that such natural persons have indeed executed consents to service of process and will allow
Commission staff to examine such consents to service of process.
The requirement that certain written representations and disclosures be made in order for a
person to be exempt from the definition of municipal advisor (where a municipal entity or obligated
person is represented by an independent registered municipal advisor with respect to the same aspects of
a municipal financial product or an issuance of municipal securities) will allow the Commission staff to
determine whether a person engaging in municipal advisory activities has failed to register with the
Commission. Further, the information will allow municipal entities and obligated persons to understand
whether a person is acting as a municipal advisor. Similarly, the exceptions from the definitions of
municipal escrow investments and proceeds of municipal securities for reasonable reliance will allow
the Commission staff to determine whether a person engaging in municipal advisory activities has failed
to register with the Commission.

3.

Use and Consideration of Information Technology

The rules require applicants and registered municipal advisors to electronically file Forms MA,
MA-I, MA-NR, and MA-W through EDGAR. By requiring submission of information through
EDGAR, Commission staff is able to efficiently retrieve and analyze the data it needs, which enhances
the Commission’s ability to effectively carry out its mission with respect to municipal advisory
activities. Municipal entities, obligated persons, the general public, and others are also able to access
information about municipal advisors electronically through the Commission’s EDGAR system and
easily cross-reference information submitted through the Investment Adviser Registration Depository
(“IARD”) and Central Registration Depository (“CRD”) systems operated by the Financial Industry
Regulatory Authority (“FINRA”). Information submitted on Form MA and Form MA-I will also be
tagged in XML format, which may improve the Commission staff’s ability to retrieve and analyze data
and could allow municipal entities and obligated persons to perform better research into muni cipal
advisors.
The rules also require municipal advisors to make and keep books and records relating to its
municipal advisory activities. Rule 15Ba1-8(d) permits municipal advisors to maintain and preserve the
required records on electronic storage media.

4.

Identifying and Minimizing Duplication

The Commission recognizes that some of the information that respondents would collect under
the relevant registration forms and recordkeeping rules would overlap with information previously
collected under other registration regimes or recordkeeping rules. In adopting these rules, the
Commission sought to design a registration process that is similar to other registration processes
administered by the Commission. The rules are based on rules applicable to broker -dealers and
investment advisers; similarly, Form MA is based on the Commission’s Form ADV and Form BD, and
Form MA-I is based on FINRA’s Form U4. To the extent market participants are familiar with these
existing registration processes, the Commission believes that using similar processes to register
municipal advisors will create efficiencies for market participants. In addition, the rules permit
municipal advisors, to the extent that the disclosures required on Form MA have been disclosed on Form
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ADV or Form BD, to incorporate such information by reference, which should reduce duplication and
costs for some municipal advisors.
The Commission considered but decided not to create a separate registration program for entities
that are already registered with the Commission in another capacity. The Commission does not believe
that such an approach would achieve the goal of creating a registration system specific to municipal
advisors. Form MA, while modeled primarily on Form ADV and Form BD, is designed to capture
information regarding the activities of municipal advisors and the markets that they serve that would not
otherwise be captured in other forms. This information will permit the Commission to decide whether
to grant or deny an application for registration; to manage the Commission’s regulatory and examination
programs; and to make such information available to the MSRB to b etter inform its regulation of
municipal advisors. In addition, having information about municipal advisors in a single location could
improve the municipal advisor selection process.
Further, the Commission believes that, based on the expertise and experience of its enforcement
and examinations staff, for purposes of regulation, it is appropriate to collect information regarding the
financial industry and other activities of associated persons involved in the municipal securities market,
including swap dealers, major swap participants, and engineers and engineering firms. The Commission
believes that to allow investment advisers to register as municipal advisors using Form ADV would not
provide comparable information about certain associated persons of municipal advisors.
In addition, requiring municipal advisors to file a registration form specifically tailored to their
municipal advisory activities is consistent with the broader public interest to make available to the
public information about municipal advisors. Absent a form specific to municipal advisors, a municipal
entity or obligated person seeking information about a municipal advisor may not realize that the data
was available on Form BD or Form ADV. The Commission believes that persons seeking to compile,
compare, and analyze data pertaining to the entire universe of registered municipal advisors, and
regulators overseeing compliance with the rules and regulations applicable to municipal advisors, should
be able to access relevant information easily within one system.
With respect to the recordkeeping requirements, the Commission has reduced duplication by
adopting recordkeeping requirements that are consistent with other regulations under the securities laws.
The Commission determined not to create a unique recordkeeping requirement for municipal advisors
because it expects that many entities already registered with the Commission in another capacity, such
as investment advisers and broker-dealers, would likely incur higher, and in many ways redundant, costs
to comply with this type of regime. If the Commission established a unique recordkeeping requirement
for municipal advisors, the Commission believes that many municipal advisors would incur higher costs
due to the inability to leverage experience, systems, and practices developed to comply with the similar
recordkeeping practices under federal securities law.

5.

Effect on Small Entities

The Commission’s rules do not define “small business” or “small organization” for purposes of
municipal advisors. 21 At the time the Commission adopted the rules and forms, the Small Business
Administration (“SBA”) defined a “small business concern,” for purposes of entities that provide

21

For example, Exchange Act Rule 0-10 defines which regulated entities qualify as small entities for purposes of the
Regulatory Flexibility Act (“RFA”), but that rule does not speak to municipal advisors. See 17 CFR 240.0-10.

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financial investments and related activities, as a business that had annual receipts of less than $7 million
during the preceding fiscal year and is not affiliated with any person that is not a small business or small
organization. 22 The Commission incorporated the SBA’s definition in Item 10 of Form MA and is using
that definition to define municipal advisors that are small entities for purposes of the RFA. 23 The
Commission estimates that there are approximately 320 municipal advisors currently registered with the
Commission that are small entities, and expects that approximately 35 of the 45 municipal advisors that
would be required to register with the Commission during the next three years would be small entities
subject to the final rules and forms. 24 The table below summarizes the Commission’s estimates of the
total number of respondents for each information collection that will be small entities annually in each
of the next three years:

Information Collections (ICs)

Form MA: Application for Municipal
Advisor Registration
Form MA-I: Information Regarding Natural
Persons Who Engage in Municipal
Advisory Activities
Form MA-W: Notice of Withdrawal from
Registration as a Municipal Advisor
Form MA-NR: Designation of U.S. Agent
for Service of Process for Non-Residents

Estimated Number of
Respondents That
Will Be Small Entities
Annually in Each of
the Next Three Years
305 25
305 26
14 27
3 28

22

See Final MA Rule Adopting Release, 78 FR at 67627 (citing 13 CFR 121.201). Under Section 601(3) of the RFA, the
term “small business” is defined as having “the same meaning as the term ‘small business concern’ under section 3 of the
Small Business Act, unless an agency, after consultation with the Office of Advocacy of the Small Business
Administration and after opportunity for public comment, establishes one or more definitions of such term which are
appropriate to the activities of the agency and publishes such definition(s) in the Federal Register.” 5 U.S.C. 601(3).

23

See Final MA Rule Adopting Release, 78 FR at 67557.

24

11.67 (estimated average number of new Form MA filers that were small entities over the last three years ((10 (2023) +
14 (2024) + 11 (2025)) ÷ 3) ÷ 15 (estimated average number of new Form MA filers over the last three years (see infra
Section 12.a.)) = 77.8% (estimated percentage of new Form MA filers that are small entities). 0.778 x 45 (estimated
number of new Form MA filers over three years (see infra Section 12.a.)) = 35.01.

25

320 (estimated number of municipal advisors currently registered with the Commission that are small entities) ÷ 419
(estimated number of municipal advisors registered with the Commission as of December 31, 2025 (see infra Section
12.a.)) = 76.37% (estimated percentage of municipal advisors that are small entities). 0.7637 x 399 (estimated average
number of municipal advisors in each of the next three years (see infra Section 12.a.)) = 304.72.

26

See supra note 25.

27

13.67 (estimated average number of Form MA-W filers that were small entities over the last three years ((13 (2023) + 15
(2024) + 13 (2025)) ÷ 3) ÷ 21 (estimated average number of Form MA-W filers over the last three years (see infra
Section 12.c.) = 65.1% (estimated percentage of Form MA-W filers that are small entities). 0.651 x 21 (estimated
number of Form MA-W filers in each of the next three years (see infra Section 12.c.)) = 13.67.

28

2.67 (estimated average number of Form MA-NR filers that were small entities over the last three years ((3 (2023) + 1
(2024) + 4 (2025)) ÷ 3) ÷ 4 (estimated average number of Form MA-NR respondents over the last three years (see infra

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Consent to Service of Process from Certain
Associated Persons
Rule 15Ba1-8: Books and Records to Be
Made and Maintained by Municipal
Advisors
Rule 15Ba1-1(d)(3)(vi): Exemption When a
Municipal Entity or Obligated Person Is
Represented by an Independent Registered
Municipal Advisor
Rule 15Ba1-1(h)(2): Exception to
Definition of Municipal Escrow
Investments
Rule 15Ba1-1(m)(3): Exception to Definition
of Proceeds of Municipal Securities

305 29
305 30

61 31

478 32
509 33

The Commission notes that municipal advisors are required by statute to register with the
Commission. As such, the final rules and forms affect municipal advisors required to register with the
Commission, including small entities. The Commission does not believe differing compliance or
reporting requirements or an exemption from coverage of the final rules and forms, or any part thereof,
for small entities would be appropriate or consistent with investor protection or with the Commission’s
understanding of Congress’s intent to have the Commission register municipal advisors and oversee
their activities. Because the Commission believes that the protections of Section 15B of the Exchange
Act, as amended by Section 975 of the Dodd-Frank Act, are intended to apply equally to clients of both
large and small municipal advisory firms, the Commission believes it would be inconsistent with the
purposes of the Exchange Act to specify different requirements for municipal advisors that qualify as
small entities under the rules. Thus, the rules are designed to impose only those burdens necessary to
accomplish the objectives of the Dodd-Frank Act and minimize any significant adverse impact on small
entities.
Finally, the staff of the SEC’s Office of Municipal Securities (“OMS”) makes efforts to
minimize burdens on small entities through ongoing educational initiatives and market outreach on the

Section 12.d.)) = 66.75% (estimated percentage of Form MA-NR respondents that are small entities). 0.6675 x 4
(estimated number of Form MA-NR respondents in each of the next three years (see infra Section 12.d.)) = 2.67.
29

See supra note 25.

30

Id.

31

38.73% (estimated percentage of respondents seeking to rely on the independent registered municipal advisor exemption
that are small entities) (based on Form BD data )) x 157 (estimated number of respondents seeking to rely on the
independent registered municipal advisor exemption in each of the next three years) (see infra Section 12.g.)) = 60.8.

32

78.2% (estimated percentage of respondents seeking to rely on the exception to the definition of municipal escrow
investments that are small entities) (based on Form ADV data)) x 611 (estimated number of respondents seeking to rely
on the exception to the definition of municipal escrow investments in each of the next three years) (see infra Section
12.h.)) = 477.8.

33

76% (estimated percentage of respondents seeking to rely on the exception to the definition of proceeds of municipal
securities that are small entities) (based on Form ADV data)) x 669 (estimated number of respondents seeking to rely on
the exception to the definition of municipal escrow investments in each of the next three years) (see infra Section 12.i.))
= 508.4, rounded up.

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topic of municipal advisor registration. For example: (i) in September 2013, OMS published a small
entity compliance guide on the registration of municipal advisors;34 (ii) in January 2014, and in a series
of ongoing releases from 2014 to the present, OMS has answered frequently asked questions (“FAQs”)
on the registration of municipal advisors;35 and (iii) in November 2025, OMS published an
informational bulletin on how to register as a municipal advisor (compiling and summarizing preexisting
resources related to the initial SEC registration process for municipal advisors ).36 OMS maintains a
webpage where such resources are collected. 37 In addition, OMS maintains and publicizes a hotline
number (202-551-5680) and email address ([email protected]) whereby any member of the public may
inquire about the municipal advisor registration process and the final rules and forms.

6.

Consequences of Not Conducting Collection and Obstacles to Reducing
Burden

The collection of information under the rules and forms is designed to establish a permanent
registration regime and establish certain recordkeeping requirements for municipal advisors, as provided
in Section 975 of the Dodd-Frank Act. The registration regime will allow the Commission to retrieve
and analyze the data it needs more efficiently, which should enhance the Commission’s ability to carry
out its mission with respect to municipal advisory activities effectively. In addition, th e registration
regime could improve the process through which municipal entities and obligated persons select
municipal advisors and incentivize municipal advisors not to engage in misconduct. Absent the
collection of information, municipal advisors would not have a mechanism through which to satisfy the
requirement in Section 15B of the Exchange Act that they register with the Commission. In ad dition,
less frequent collection of this information would not allow the Commission and other regulators;
municipal entities and obligated persons; or investors to access up-to-date information about municipal
advisors.

7.

Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)

5 CFR 1320.5(d)(2)(i): Since Rule 15Ba1-5 requires registered municipal advisors to file
amendments to Forms MA and MA-I if certain information contained in the forms becomes inaccurate,
it is possible for a registered municipal advisor to report information to the Commission more often than
quarterly. However, this collection of information is necessary to ensure that the Commission,
municipal entities, obligated persons, and the public have access to current information regarding
municipal advisors registered with the Commission.
5 CFR 1320.5(d)(2)(iv): Rule 15Ba1-8 requires registered municipal advisors to maintain and
preserve books and records for a period of not less than five years, the first two in an easily accessible
place. This rule is modeled on Exchange Act Rules 17a-3 and 17a-4, and Rule 204-2 under the

34

See Registration of Municipal Advisors: A Small Entity Compliance Guide (Nov. 15, 2013),
https://www.sec.gov/resources-small-businesses/small-business-compliance-guides/registration-municipal-advisors.

35

See Registration of Municipal Advisors: Frequently Asked Questions (Jan. 10, 2014; additional FAQs issued in 2014,
2017, 2023, 2025, and 2026), https://www.sec.gov/about/divisions-offices/office-municipal-securities/registrationmunicipal-advisors.

36

See Informational Bulletin: How to Register as a Municipal Advisor (Nov. 19, 2025),
https://www.sec.gov/newsroom/whats-new/informational-bulletin-how-register-municipal-advisor.

37

See Office of Municipal Securities, Municipal Advisors, https://www.sec.gov/about/divisions-offices/office-municipalsecurities/municipal-advisors.

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Investment Advisers Act of 1940, and OMB has previously approved that collection with the same five year retention period. This collection of information would help to ensure that records exist of the
respondent’s municipal advisory activities and of its associated persons, and that the records could be
provided to the Commission and other regulators during an examination to evaluate the municipal
advisor’s compliance with the Exchange Act, the rules thereunder, and MSRB rules, as well as for other
regulatory purposes.

8.

Public Comment and Consultations Outside the Agency

The Commission and OMS staff participate in an ongoing dialogue with representatives of the
municipal advisor industry through public conferences, meetings, and informal exchanges. These
various forums provide the Commission and staff with a means of asce rtaining and acting upon
paperwork burdens confronting the industry.
The required Federal Register notice with a 60-day comment period soliciting comments on this
collection of information was published. 38 The Commission received two comment letters in response
to this comment solicitation. 39 In addition to the standard requests for comment (“RFCs”) that must
appear in PRA extension notices, the Commission solicited comments on 12 specific topics that were
designed to help the Commission better understand the real-world costs and burdens of municipal
advisor regulation, identify opportunities to reduce unnecessary regulatory friction, clarify areas of
interpretive uncertainty through FAQ updates or other staff statements, improve the functionality and
user experience of the EDGAR filing system, improve the public accessibility of filed forms and data,
and determine whether any aspects of the current rules, forms, or instructions should be amended or
eliminated because they impose requirements without a corresponding regulatory benefit – all with the
broader goal of ensuring that the municipal advisor registration framework operates as efficiently and
transparently as possible for municipal entities and obligated persons, investors, registrants, regulators,
and other stakeholders. 40 Both commenters responded to these RFCs, 41 as detailed below. One
commenter expressed appreciation that the Commission invited written comments on the RFCs, 42 and
that the Commission is taking this opportunity to study whether to update municipal advisor registration
rules to modernize associated filing requirements, consistent with its statutory obligations under the
PRA.43

38

See Agency Information Collection Activities; Proposed Collection; Comment Request; Extension: Rules 15Ba1 -1 to
15Ba1-8-Registration of Municipal Advisors and Forms MA, MA-I, MA-W, and MA-NR, 91 FR 40622 (July 2, 2026)
(“60-Day Notice”), available at https://www.govinfo.gov/content/pkg/FR-2026-07-02/pdf/2026-13358.pdf.

39

Letter from Susan Gaffney, Executive Director, National Association of Municipal Advisors (“NAMA Letter”), August
31, 2026; Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Gerald O’Hara, Vice
President and Assistant General Counsel, Securities Industry and Financial Markets Association (“SIFMA Letter”),
August 31, 2026. In addition, Commission staff discussed the 60-Day Notice, among other things, during three video
conferences with a representative of NAMA. See OMS Memoranda dated July 16, 2026 and August 26, 2026.

40

See 60-Day Notice, 91 FR at 40629.

41

NAMA Letter, at 1-6; SIFMA Letter, at 4-12.

42

SIFMA Letter, at 1.

43

SIFMA Letter, at 2.

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As discussed more fully below, it is the view of Commission staff that most of the comments
received either: (i) addressed the information collection burden generally but did not provide any
quantified alternative estimate or specific supporting data related to the burden that would allow the
Commission to determine what revised burden estimate would be appropriate for each rule, form, and
filing type; or (ii) recommended changes to the rules, forms, and related processes that would likely
need to be effected pursuant to a Commission rulemaking, or a rulemaking by other entities, and are
therefore beyond the scope of the PRA analysis.
Nonetheless, as discussed more fully below, the Commission is amenable to increasing its
estimated time burdens, cost equivalents, and additional cost burdens to better reflect the actual, average
burdens borne by respondents, as appropriate. Should the commenters respond to the 30-Day Notice by
providing quantified alternative estimates and specific supporting data for each burden estimate that it
asserts is too low, the Commission would take such additional comments under advisement and consider
revising its burden estimates this PRA extension cycle. In addition, as discussed more fully below,
Commission staff has determined to take concrete steps to further develop, study, and/or act upon nearly
all comments received, including comments suggesting that the Commission should: (i) define which
municipal advisors constitute “small entities” for purposes of the Regulatory Flexibility Act (“RFA”) or
municipal advisor regulation more broadly; (ii) undertake a retrospective rule review of the rules and
forms; (iii) make enhancements to the current EDGAR filing system, EDGAR Filer Manual, and
EDGAR filer support line; (iv) make enhancements to SEC.gov, including the EDGAR website, to
improve the public accessibility of registrant information; (v) provide clarification on certain aspects of
the rules and forms through public statements by Commission staff; and (vi) coordinate with the MSRB,
FINRA, and other financial regulators to identify and eliminate potential regulatory duplication related
to the municipal advisor registration process. 44

a. Estimated Time Burdens, Cost Equivalents, and Additional Cost
Burdens
One commenter stated that the Commission “vastly underestimates” the burden imposed by the
information municipal advisors are required to submit to the Commission pursuant to relevant municipal
advisor rules and forms, 45 that municipal advisors have incurred “significant costs” associated with
completing the forms, 46 and that the Commission’s estimates “have not accurately captured all of these
costs.” 47 In particular, the commenter stated the Commission should consider incorporating in its
estimates for initial registrations “start-up costs and purchases of services (e.g., paying outside
consultants, contractors, legal advisors, or subscription-based services for activities required by the rules
and forms) as well as maintenance costs.” 48 The commenter also noted that its members “typically
handle the annual review and updating of the forms completely in-house after the initial registration,” 49
and further stated that the internal time burdens of ongoing compliance and supervisory obligations “are

44

Commission staff does not commit to take any course of action beyond the steps outlined below.

45

SIFMA Letter, at 2.

46

SIFMA Letter, at 4.

47

SIFMA Letter, at 4.

48

SIFMA Letter, at 4.

49

SIFMA Letter, at 4.

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not inconsequential” and “should not be excluded” from burden considerations. 50
The other commenter similarly stated that the Commission’s estimates for completion of the
forms, internal time burdens for rule compliance, and external services are “too low” and should be
“revisited.” 51 In particular, the commenter stated that the estimated time burdens to complete the forms
should be “increased,” especially for Form MA-I, due to “difficulties navigating through the EDGAR
system.” 52 The commenter also stated that the estimated rate for internal costs of compliance should be
“reviewed” because, in the independent municipal advisor community, “nearly 80% of compliance work
is done by registered MAs, with a substantive number of those being CEO/senior leadership rather than
administrative staff.” 53 The commenter further stated that there are “significant costs” associated with
ongoing compliance and the forms that the Commission should account for, or consider, in its
estimates,54 including that: (1) “some” municipal advisors utilize external counsel and compliance
consultants to complete the forms (e.g., “many” firms seek advice from outside counsel or consultants to
understand the parameters of questions on the forms, such as outside business activity on Form MA-I);55
(2) “[m]any” firms procure “various systems” to store and monitor their communications and
documentation, “paying anywhere from $1,500 - $100,000+ a year for these additional systems;” 56 and
(3) firms incur both internal and external costs associated with rule compliance burdens that have
“grown over time,” including “communications recordkeeping requirements that lack adequate SEC
guidance,” “documenting recommendations and other MA activity,” and “improving firm records
following public comments made by the Commission and OMS staff, SEC enforcement actions, and
findings during the Exams process.” 57
After consideration, the Commission has not made any changes to its burden estimates based on
these comments. The Commission is amenable to increasing its estimated time burdens, cost
equivalents, and additional cost burdens to better reflect the actual, average burdens borne by
respondents, as appropriate. Commission staff notes, however, that the commenters generally did not
provide any quantified alternative estimates or specific data to support their assertions that the
Commission’s various burden estimates are too low. 58 Commission staff emphasizes that the present

50

SIFMA Letter, at 4.

51

NAMA Letter, at 1.

52

NAMA Letter, at 1.

53

NAMA Letter, at 2; see also id. (“Recent discussion of compliance costs in the MSRB Notice SR 2026-04, page 24
(https://www.sec.gov/files/rules/sro/msrb/2026/34-106014.pdf), should also be reviewed.”).

54

NAMA Letter, at 1-2.

55

NAMA Letter, at 1.

56

NAMA Letter, at 2.

57

NAMA Letter, at 2.

58

With respect to estimated time burdens, for instance, the only quantified alternative estimate provided was one
commenter stating that “completing a filing can take up to an hour,” but that commenter did not specify which form or
filing type it was referring to, and did not provide any specific supporting data for this purported burden, such as how
many of its members were surveyed, how its members arrived at this estimate, or why this estimate is representative of
the hours burden for the full population of municipal advisor registrants. See SIFMA Letter, at 8. Likewise, with respect
to additional cost burdens, the only quantified estimate provided was one commenter stating that many firms pay
“anywhere from $1,500 - $100,000+ a year” for various systems to store and monitor communications and
documentation, but that commenter did not provide any specific supporting data for this purported burden, such as how
many of its members were surveyed, how its members arrived at this estimated range, what the average burden was for

U.S. Securities and Exchange Commission (SEC)
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PRA extension process, including the notice and comment process provided by the 60 -Day Notice and
30-Day Notice, is the process through which the Commission revisits, reviews, and revises its current
burden estimates, and that certain data necessary to evaluate potential revisions to the current burden
estimates is available only from market participants based on their own experience with the inform ation
collection. Should the commenters respond to the 30 -Day Notice by providing quantified alternative
estimates and specific supporting data for each burden estimate that it asserts is too low, the
Commission would take such additional comments under advisement and consider revising its burden
estimates this PRA extension cycle. Alternatively, the commenters may meet with OMS staff, as
always, to discuss potential revisions for the next PRA extension cycle in approximately three years.
In addition, with respect to the Commission’s estimated rates for internal costs of compliance,
Commission staff acknowledges that executives, senior leadership, or owners of smaller, independent
municipal advisory firms may often be the individuals performing the relevant compliance work, but
Commission staff determined it would be more appropriate to base these estimated cost equivalents on
the type of work being performed, rather than merely using the job title or primary role of the person
performing that work which may overestimate the market value of the work being performed.
Commission staff further notes that the cost equivalents are intended to estimate the average burden
across all types of municipal advisory firms.
Finally, Commission staff notes that the estimates set forth in the 60-Day Notice do account for
certain additional cost burdens, including all new municipal advisory firms consulting with outside
counsel or outside compliance consultants for one hour, at an average rate of $575/hour, and all Form
MA-NR filers hiring outside counsel for three hours as part of providing an opinion of counsel, at an
average rate of $528/hour. Commission staff further notes that the additional cost burdens are intended
to estimate the average burden across all types of municipal advisory firms. 59

b. Small Entity Estimates
Although the Commission has historically estimated that no small entities rely on the
independent registered municipal advisor exemption under Rule 15Ba1 -1(d)(3)(vi), both commenters
stated that small entities rely, 60 or “likely” rely, 61 on that exemption. One commenter stated that it does
not have any suggestions as to how the Commission should estimate how many small entities rely on the
exemption.62 The other commenter stated that the Commission should “reconsider the approach” it uses
to estimate and define the types of firms that rely on the exemption, and should “review and solicit
additional input” on its estimates for the number of respondents that utilize this exemption and the time

the relatively wide numerical range presented, or why this estimate is representative of the hours burden for the full
population of municipal advisor registrants. See NAMA Letter, at 2. In addition, neither commenter indicated how
many registered municipal advisory firms are currently members of their organizations, i.e., what proportion of the
municipal advisor registrant population is represented in the comments provided.
59

See, e.g., SIFMA Letter, at 4 (noting its members “typically handle the annual review and updating of the forms
completely in-house after the initial registration”).

60

SIFMA Letter, at 4-5.

61

NAMA Letter, at 2.

62

SIFMA Letter, at 5.

U.S. Securities and Exchange Commission (SEC)
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and costs associated with the requirements. 63
After consideration, the Commission agrees with the commenters, has revised its approach, and
is now estimating that 61 small entities will rely on the independent registered municipal advisor
exemption in each of the next three years. 64 Commission staff would welcome any additional input that
the commenters wish to provide.

c. Small Entity Definition
Both commenters stated that the Commission should consider defining which municipal advisors
constitute “small entities” for purposes of the RFA or municipal advisor regulation more broadly. 65 One
commenter stated that the Commission should conduct “extensive discussions” on how to define “small
entities” for purposes of municipal advisor regulation, including what a small entity designation means
in relation to the SEC’s municipal advisor rules.66 That commenter also stated the SEC and MSRB
should coordinate efforts on defining small entities to avoid having two separate standards. 67
As for what metric the Commission should use to determine small entity status, one commenter
stated that it does not have any suggestions at this time, 68 but noted that using the SBA’s definitions to
define a small municipal advisor is an “ill-advised methodology, particularly given the breadth of
current proposals.” 69 The other commenter similarly noted that “it is difficult to determine what metric
is most useful,” how to approach the topic should be a “specific initiative,” and a consideration is that,
“if utilizing SBA thresholds, all MA firms may be considered small within the scope of all financial
entities,” as the relevant threshold increased from $7 million to $47 million in 2014, and the SBA’s
current proposals, if finalized, would increase the relevant threshold to $1.011 billion. 70 Both
commenters identified FINRA’s “Small Firm” category of 1-150 registered persons as an alternative
regulatory definition that currently exists. 71
After consideration, the Commission has not made any changes to its burden estimates based on
these comments. Commission staff notes that any definition of which municipal advisors constitute
“small entities” for purposes of the RFA or municipal advisor regulation more broadly would need to be

63

NAMA Letter, at 2.

64

See infra Section 5.

65

NAMA Letter, at 5; SIFMA Letter, at 12.

66

NAMA Letter, at 5.

67

NAMA Letter, at 5.

68

SIFMA Letter, at 12.

69

SIFMA Letter, at 5 note 7 (citing https://legacy.sba.gov/article/2026/08/20/sba -proposes-overhaul-simplify-smallbusiness-classification-expand-access-federal-programs).

70

NAMA Letter, at 5.

71

See SIFMA Letter, at 5 note 7 (“FINRA Bylaws do define ‘Small Firm’ to mean any broker or dealer admitted to
FINRA membership that has at least 1 and no more than 150 registered persons.”); NAMA Letter, at 5 (“Considerations
for this conversation include . . . whether approaches used to define small entities by other regulators (e.g., FINRA’s
small firm category of 1-150 registered persons) could work for MA regulations.”).

U.S. Securities and Exchange Commission (SEC)
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effected pursuant to a Commission rulemaking and are beyond the scope of the PRA analysis.
Nonetheless, staff agrees with the commenters that the Commission should consider defining which
municipal advisors constitute “small entities” for purposes of the RFA or m unicipal advisor regulation
more broadly, and that the SEC and MSRB should coordinate any effort to define small entities. To that
end, staff intends to hold discussions with market participants, the MSRB, FINRA, and other
stakeholders to inform a potential recommendation that the Commission engage in rulemaking related to
this topic.

d. Enhancements to the Rules, Forms, and Registration Process
Amendments to the Rules and Forms: One commenter recommended that the Commission
conduct “a complete retrospective rule review of Rules 15Ba1 -1 to 15Ba1-8, and associated forms, as
the municipal advisor registration regime is unnecessarily complex and burdensome, and should be
streamlined to appropriately balance these burdens with the benefits of the rules.” 72
The other commenter stated that the Instructions for the Form MA Series could use a “major
review” to ensure that it clearly explains the forms and the process to complete the forms, 73 and
recommended that it would be helpful for the Commission to further clarify three provisions of the
books and records requirements: (1) Rule 15Ba1-8(a)(1), including the phrase “relating to” municipal
advisor activity; (2) Rule 15Ba1-8(a)(4), including the phrase “document created by the municipal
advisor that was material to making a recommendation;” and (3) Rule 15Ba1 -8(a)(5), including the
phrase “otherwise relating to the business of such municipal advisor as such.” 74 That commenter stated,
however, that “[a]dditional discussions should occur to determine if clarifications to MA Forms (in
order to ease their use) as well as various segments of the MA Rule (to aid compliance), could be met
with FAQs and guidance or if changes to the MA Rule are needed.” 75
In addition, the first commenter identified “excessive duplication in the filing requirements” as
one aspect of the rules and forms that impose a requirement with no corresponding regulatory benefit. 76
The other commenter identified “the length of the work history needed for younger individuals” 77 (i.e.,
“[r]equirements to list 10 years’ experience” 78) as an example of such an aspect.
After consideration, the Commission has not made any changes to its burden estimates based on
these comments. Commission staff notes that any amendments to the rules and forms would need to be

72

SIFMA Letter, at 2; see also SIFMA Letter, at 2, 4, 5, 11, 12 (stating, for example, that “SIFMA urges the Commission
to undertake a retrospective review of Rules 15Ba1-1 to 15Ba1-8, and associated forms, and revise these rules and forms
to account for the current municipal securities market, and technological advances, and more appropriately balance
reporting burdens with the disclosures necessary for the Commission to carry out its statutory obligations with respect to
municipal securities.”).

73

NAMA Letter, at 4.

74

NAMA Letter, at 4.

75

NAMA Letter, at 4.

76

SIFMA Letter, at 11.

77

NAMA Letter, at 4.

78

NAMA Letter, at 6.

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effected pursuant to a Commission rulemaking and are beyond the scope of the PRA analysis.
Nonetheless, staff agrees with the commenters that the Commission should engage in a retrospective
review of the rules, forms, and instructions. To that end, staff intends to hold discussions with market
participants, the MSRB, FINRA, and other stakeholders to inform the nature a nd scope of that review,
and to better understand which aspects of the rules, forms, and instructions are viewed as being more
appropriate for amendment rather than clarification in staff statements or interpretative guidance.
Enhancements to the EDGAR Filing System: Both commenters recommended that the
Commission consider making enhancements to the current EDGAR filing system to improve the user
experience of electronically completing Forms MA, MA-I, and MA-W.79
The recommended enhancements include: (1) improving the accessibility of historical filings
accepted by EDGAR;80 (2) addressing character limitations and limits on the number of entries that can
be made for certain Items;81 (3) adding a “Delete” button besides the current “Edit” button for certain
Items;82 (4) for each Regulatory Action Disclosure Reporting Page, adding the “Disclosure Occurrence
No.” as “an additional data point;” 83 (5) adding pop-up boxes to key areas of the forms that explain the
information sought, 84 such as the definitions of italicized words or phrases; 85 (6) making the forms
“more linear,” so that the preparer can enter the information following the question rather than jump
around;86 (7) for Form MA-I amendments, allowing users to search for the covered individual directly
rather than using a prior accession number, and for disassociating amendments, adding a separate Form
MA-I “termination workflow or dedicated link;” 87 (8) making the field entry rules consistent so, for
example, there are no longer varying capitalization requirements; 88 (9) improving the EDGAR login
process;89 (10) improving the speed at which the EDGAR system performs; 90 (11) improving the process
of saving information in EDGAR;91 (12) adding the ability to input overlapping dates in areas such as

79

SIFMA Letter, at 6-10; NAMA Letter at 3, 6.

80

SIFMA Letter, at 6-7.

81

SIFMA Letter, at 7.

82

SIFMA Letter, at 7.

83

SIFMA Letter, at 7.

84

NAMA Letter, at 4.

85

SIFMA Letter, at 7.

86

SIFMA Letter, at 7.

87

SIFMA Letter, at 8.

88

SIFMA Letter, at 8; NAMA Letter, at 6.

89

NAMA Letter, at 3; see also NAMA Letter, at 6 (“Log in process to use EDGAR can take an undue amount of time due
to its quirks.”).

90

SIFMA Letter, at 8.

91

NAMA Letter, at 3; see also NAMA Letter, at 6 (“There are problems with being able to save form information and be
able to return to same place and finish completing the form. This causes more time to reenter all of the information.”).

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prior work history;92 (13) adding the ability to make a business address change in a more uniform
manner rather than one by one on Form MA-Is;93 (14) providing notice of which web browsers work
when updating forms;94 (15) pre-populating certain information within EDGAR; 95 (16) improving the
process of inputting residential address changes; 96 (17) clarifying that “all possible titles” must be listed
in Schedule A-2 of Form MA or the form will be rejected;97 and (18) making accession numbers more
readily accessible. 98
Both commenters also recommended improvements to the EDGAR validation and
acceptance/rejection process for submitted forms. 99 One commenter stated that the process should be
“streamlined,” as there are varied experiences and wait times between firms. 100 The other commenter
stated that there should be a “pre-submission validation feature,” rather than a firm waiting to receive a
response from the Commission that the filing was accepted or rejected, and recommended that a reason
be provided if a filing is not accepted. 101
One commenter further recommended directly integrating the SEC’s EDGAR system with the
FINRA Gateway system, including pre-populating information from FINRA Gateway and
synchronizing FINRA Form U4 with SEC Form MA-I.102 Under this recommendation, municipal
advisory firms that are also FINRA members would not have to duplicate information reported in an
individual’s initial Form MA-I filing with information reported to open a Series 50 exam, and
information filed on Form BD with information reported in a Form MA, including in amendments, 103
and that any changes to Form MA-I should automatically update Form U4, and vice versa. 104 This
commenter also recommended that portions of Form MA-I should be able to be routed directly to the
representative for completion, and to have questions added to the Form U4 that would auto -route to the

92

NAMA Letter, at 3; see also NAMA Letter, at 6 (“Dates at times are not accepted even though input correctly .”);
NAMA Letter, at 6 (“Doesn’t allow for overlapping work experiences for the same person.”); NAMA Letter, at 6
(“[O]rdering of work and living experience, inability to overlap months means work history makes the information
submitted inaccurate.”).

93

NAMA Letter, at 3.

94

NAMA Letter, at 6.

95

NAMA Letter, at 6 (“Frustrating that on the initial page that not all fields (CCC) prepopulate when you login.”).

96

NAMA Letters, at 6 (“Residential address changes. There is a need to be careful to not override the current address with
the new address without maintaining the old address in the list.”).

97

NAMA Letter, at 6.

98

NAMA Letter, at 6.

99

SIFMA Letter, at 8; NAMA Letter, at 6.

100

NAMA Letter, at 6.

101

SIFMA Letter, at 8.

102

SIFMA Letter, at 7-8.

103

SIFMA Letter, at 7.

104

SIFMA Letter, at 8.

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MSRB instead of needing to separately complete MSRB Form A-12.105 This commenter further
recommended that FINRA Form U5 should be used to auto -fill disassociating Form MA-I
amendments.106
Finally, one commenter recommended that OMS consider working with a group of municipal
advisors to walk through the forms step-by-step to better understand areas that are “confusing” or
“problematic” to complete. 107
After consideration, the Commission has not made any changes to its burden estimates based on
these recommendations. Commission staff notes that any changes to the EDGAR filing system are
beyond the scope of the PRA analysis as they would involve internal, administrative processes which
may need to be effected pursuant to a Commission rulemaking. Nonetheless, staff agrees with the
commenters that many aspects of the EDGAR filing system could be enhanced to improve the user
experience of electronically completing the forms, including for multi-registered municipal advisors,
and that it would be beneficial for staff to walk through the forms with market participants to better
understand areas that are confusing or problematic to complete. To that end, staff intends to hold
discussions with market participants, the MSRB, FINRA, and other stakeholders to further develop the
enhancements recommended by the commenters, to identify additional enhancements, and to determine
the feasibility of integrating EDGAR and FINRA Gateway. Staff also intends to coordinate with the
Commission’s EDGAR Business Office (“EBO”) to begin implementing certain recommended
enhancements.
Redesign of EDGAR and the Registration Process: One commenter stated that the EDGAR
system could benefit from “being updated, if not overhauled,” to improve user experiences. 108 The other
commenter stated that the Commission could consider a more holistic review of the various registration
and membership materials broker-dealers are required to complete across the regulatory spectrum, and
recommended that the Commission undertake a “complete redesign” of EDGAR and the registration
process.109 To that end, the commenter purported to summarize the various forms that a broker-dealer
operating a municipal securities business must submit to the SEC, FINRA, the MSRB, and/or the
banking regulators, and recommended the creation of a centralized regis tration portal or regulatory
registration “super app” that would enable a broker-dealer to initiate and update its registrations with
various regulators in one central location. 110
After consideration, the Commission has not made any changes to its burden estimates based on
these recommendations. Commission staff notes that certain recommendations would need to be
effected pursuant to a Commission rulemaking and are beyond the scope of the PRA analysis.
Nonetheless, staff agrees that the Commission should consider the costs and benefits of potentially
redesigning EDGAR and the registration process in a more holistic manner, including the potential

105

SIFMA Letter, at 8.

106

SIFMA Letter, at 10.

107

NAMA Letter, at 3.

108

NAMA Letter, at 3.

109

SIFMA Letter, at 8.

110

SIFMA Letter, at 8-10.

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development of a centralized registration portal or regulatory registration “super app” for multi registered firms in the municipal securities industry. To that end, staff intends to hold discussions with
market participants, the MSRB, FINRA, the federal banking regulators, and other stakeholders to further
develop the recommendations offered by the commenters, and to determine the feasibility of those
recommendations.
Reducing Regulatory Duplication Between SEC, MSRB, FINRA, and Other Financial
Regulators: In addition to the recommendations above, one commenter recommended that “the
Commission work with other federal financial regulators, such as the MSRB and FINRA (both of which
are subject to the Commission’s jurisdiction), to identify and eliminate pote ntial regulatory
duplication.” 111 This commenter stated, for example, that the MSRB’s separate registration requirement
under MSRB Rule A-12 creates unnecessary duplication. 112 This commenter recommended
“eliminating A-12,” and “merely requiring an annual certification for any technical, data billing,
regulatory, or compliance contact information the MSRB may need, similar to FINRA’s process.” 113
The other commenter stated that “[t]here is no doubt that the information collected in Form MA and
Form A-12 are redundant” and recommended that the SEC and MSRB “engage in determining the
differences in the forms and what could be done to ease the dual registration requirements.” 114
With respect to recordkeeping, the other commenter similarly recommended that there should be
a “discussion and initiative” to address the SEC and MSRB’s two separate municipal advisor
recordkeeping frameworks to “determine where/how there could be a roadmap to especially assist newer
and smaller firms,” and to find ways to also aid “Broker-Dealer/MA Firms with their numerous
recordkeeping requirements across regulators.” 115
After consideration, the Commission has not made any changes to its burden estimates based on
these recommendations. Commission staff notes that certain recommendations would need to be
effected pursuant to a Commission and/or MSRB rulemaking and are beyond the scope of the PRA
analysis. Nonetheless, staff agrees with the commenters that the Commission should work with other
federal financial regulators to identify and eliminate potential regulatory duplication, that the MSRB’s
separate registration requirement under MSRB Rule A-12 likely creates unnecessary duplication, and
that it would be beneficial to discuss ways that the Commission can help newer, smaller, and multi registered municipal advisors navigate the current recordkeeping frameworks. To that end, staff intends
to hold discussions with market participants, the MSRB, FINRA, the federal banking regulators, and
other stakeholders to address these comments and/or further develop the actions recommended by the
commenters.

111

SIFMA Letter, at 11; see also SIFMA Letter, at 2 (“SIFMA also recommends that the Commission work with other
federal financial regulators to identify and eliminate potential regulatory duplication, consistent with the Commission’s
recent initiatives to harmonize regulatory approaches across the federal government. Therefore, we encourage the
Commission to consider the benefits of reviewing and harmonizing potentially duplicative regulatory requirements that
exist across the rule sets of the Commission, the MSRB, FINRA, and the federal banking regula tors.”).

112

SIFMA Letter, at 11.

113

SIFMA Letter, at 11.

114

NAMA Letter, at 4.

115

NAMA Letter, at 6.

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Amendments to the EDGAR Filer Manual: One commenter stated that making EDGAR
filings is “often an arduous process” and the “[EDGAR] Filer Manual may be technically correct but is
not a very user-friendly document.” 116
After consideration, the Commission has not made any changes to its burden estimates based on
this comment. Commission staff notes that any amendments to the EDGAR Filer Manual would need to
be effected pursuant to a Commission rulemaking and are beyond the scope of the PRA analysis.
Nonetheless, staff agrees with the commenter that aspects of the EDGAR Filer Manual could be
enhanced to improve user experience. To that end, staff intends to hold discussions to determine the
feasibility of those enhancements.
Enhancements to the EDGAR Filer Support Line: One commenter stated that “MA Firms have
called the assistance line when experiencing problems making a filing, with mixed results and typically
taking more time than should be expected.” 117
After consideration, the Commission has not made any changes to its burden estimates based on
this comment. Commission staff notes that any changes to the EDGAR filer support line would involve
internal, administrative processes and are beyond the scope of the PRA analysis. Nonetheless, staff
agrees that the EDGAR filer support line should aim to provide consistent, accurate, and ti mely
information to all municipal advisors that call in. To that end, staff intends to hold discussions with
market participants to identify potential enhancements that could improve the user experience of callers.
Staff also intends to coordinate with EBO to determine the feasibility of those enhancements, and to
potentially implement those enhancements.

e. Enhancements to the Public Accessibility of Registrant Information
Enhancements to SEC.gov, Including the EDGAR Website: One commenter stated that the
information filed in EDGAR is not presented in a manner that is easy to access, particularly for
“infrequent users” of EDGAR, and those who may access the system to confirm that a firm or
professional is registered and understand pertinent information that may be included in Form MA or
MA-I (e.g., a disciplinary action). 118 This commenter stated that “[f]inding ways to improve the user
experience would be helpful for a variety of market participants.” 119
One commenter stated that the list of registered entities and qualified municipal advisor
professionals that appear on MSRB.org is “much more user-friendly” than the list of SEC-registered
municipal advisors that appears on SEC.gov, including because no file needs to be downloaded, and
because the MSRB’s list include hyperlinks to EDGAR. 120 The other commenter agreed that “the
MSRB has a list of MA and BD firms and individual practitioners that is presented in a straightforward

116

NAMA Letter, at 4.

117

NAMA Letter, at 4.

118

NAMA Letter, at 3.

119

NAMA Letter, at 3.

120

See SIFMA Letter, at 10 (citing MSRB, Registered Firms and Qualified Municipal Advisor Professionals,
https://www.msrb.org/Municipal-Advisors; SEC, Information About Registered Municipal Advisors,
https://www.sec.gov/data -research/sec-markets-data/information-about-registered-municipal-advisors).

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manner, and that should be maintained.” 121
With respect to the “Statistics and Data Visualizations” page on SEC.gov related to SEC registered municipal advisors, 122 one commenter stated that “[t]he only additional statistics and data
visualizations that might be helpful include further information regarding solicitor municipal advisors,
such as whether they are multi-registered or municipal advisor-only firms, and their respective firm
size.”123
After consideration, the Commission has not made any changes to its burden estimates based on
these comments. Nonetheless, staff agrees with the commenters that aspects of SEC.gov, including the
EDGAR website and the Commission’s list of SEC-registered municipal advisors, could be enhanced to
improve the user experience of accessing registrant information. Staff is also coordinating with EBO to
begin implementing certain enhancements to the EDGAR website, and is coordinating with the
Commission’s Division of Economic and Risk Analysis (“DERA”) to include further information
regarding SEC-registered solicitor municipal advisors on the “Statistics and Data Visualizations” page
on SEC.gov.
Enhancements to MSRB.org: One commenter stated that the coordination between EDGAR
and the MSRB is “suboptimal,” that there are “frequent disconnects” with information submitted to
EDGAR not making it to the MSRB website, and that firms often need to contact the MSRB to correct
data that originated in EDGAR (e.g., “when a registrant takes the Series 50 before the Series 52”). 124
After consideration, the Commission has not made any changes to its burden estimates based on
this comment. Commission staff notes that this comment appears to concern issues with the
presentation of information on MSRB.org, which is maintained by the MSRB, rather than data quality
issues involving information that originated in EDGAR. Nonetheless, staff agrees that any EDGAR data
the MSRB presents on its website should be timely and accurate. To that end, staff intends to hold
discussions with market participants to better understand this comment, and to coordinate with the
MSRB on addressing this comment.

f. Stakeholder Engagement and Public Statements by Commission
Staff
Consultations Outside the Agency: One commenter stated that, over the years, engagement with
OMS has been “accessible and helpful,” including staff participation at industry conferences, formal
meetings, and through informal exchanges.125 As for what additional steps the Commission and OMS staff
should take to ascertain and act upon burdens confronting the municipal advisor industry on an ongoing
basis, this commenter stated that, in recent years, OMS has become “more active” in speaking about market

121

NAMA Letter, at 4.

122

SEC, Statistics & Data Visualizations: Municipal Advisors, https://www.sec.gov/data -research/statistics-datavisualizations/municipal-advisors.

123

SIFMA Letter, at 11

124

SIFMA Letter, at 10.

125

NAMA Letter, at 2.

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practices, “which, at times, has created challenges for MAs to understand how best to address these matters
in their practice and within their compliance program.” 126 That commenter recommended that OMS
“continue its outreach to market participants especially related to how OMS statements impact market
participants, any formal outputs produced by OMS (including MA FAQs), and continue engagement as
OMS staff develops materials for MAs and the broader municipal securities sector.” 127
The other commenter stated that the Commission should be “more transparent about pending
projects” and recommended that the Commission “engage in more interactive conversations with market
participants, as opposed to one-way interactions.” 128 As an example, this commenter stated that OMS
staff’s “recently revised Municipal Advisor FAQs . . . were a surprise to most in the market and were not
subject to comment or industry feedback.” 129 That commenter further stated that, “while we always
welcome dialogue, true and durable reforms to reduce burdens confronting the municipal advisor
industry, and the municipal securities industry more broadly, can only come from Commission
rulemaking.” 130
After consideration, the Commission has not made any changes to its burden estimates based on
these comments. Commission staff appreciates this feedback, and intends to hold discussions with
market participants to address these comments. The comments concerning the Municipal Advisor FAQs
are further addressed below.
Clarifications in Public Statements by Commission Staff: One commenter recommended that
Commission staff consider clarifying a number of areas related to the registration of municipal advisors
via public statements, such as in speeches or in updates to the Registration of Municipal Advisors
FAQs.131 This commenter stated that “[o]ne of the best ways the SEC can help smaller firms, if not all
firms, with their compliance duties would be to revise and develop straightforward – in plain English –
FAQs and guidance related to the MA Rule.” 132 This commenter’s recommendations include: (1)
making the FAQs “better organized and clearer” so that the audience can “readily have take-aways without
consulting counsel;”133 (2) issuing “further FAQs on MA activity and recordkeeping guidance (including

126

NAMA Letter, at 2.

127

NAMA Letter, at 2.

128

SIFMA Letter, at 3.

129

SIFMA Letter, at 5; see also SIFMA Letter, at 5 (“The recent Municipal Advisor FAQs include the usual caveat that the
Commission considers them to be a statement of Commission staff and that they ‘have no legal force or effect, they do
not alter or amend applicable law, and they create no new or additional obligations for any person.’ In practice,
however, market participants review, interpret, and attempt to implement Commission FAQs into their supervisory and
compliance processes and procedures. In some instances, staff FAQs may raise additional interpretive questions, which
creates compliance risk. Even though the Commission disclaims that FAQs have no legal force or effect, in practice,
SEC and FINRA examiners rely on and reference staff FAQs in conducting reviews and helping to inform their own
views of industry best practices.”).

130

SIFMA Letter, at 5.

131

NAMA Letter, at 3, 6.

132

NAMA Letter, at 5.

133

NAMA Letter, at 3.

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for communications and making recommendations);” 134 (3) engaging in “[f]urther discussion on the SEC’s
MA statutory fiduciary duty in conjunction with MSRB Rule G-42 . . . to create the appropriate parameters
of a firm’s MA work and corresponding compliance mandates;” 135 (4) clarifying “whether an independent
contractor is an employee” for purposes of Item 4 of Form MA; 136 (5) clarifying when a firm must amend
Item 4 of Form MA where the instructions permit certain “approximate” answers; 137 (6) clarifying
electronic recordkeeping requirements, including questions related to the maintenance of books and records
using cloud-based services,138 and whether it could be sufficient to “create and produce on request” with
respect to electronic records;139 (7) clarifying books and records requirements related to written consents to
service of process;” 140 (8) clarifying whether a municipal advisor’s registration with the Commission is
terminated on the date the Form MA-W is submitted to EDGAR, or the date when the Form MA-W is
posted on EDGAR;141 and (9) discussing the independent registered municipal advisor exemption and how
it is and can be utilized. 142
The other commenter stated that “clarifying or changing existing regulations via public
statements and speeches is inadequate and an unfair process for regulated entities,” 143 and recommended
that any “major clarifications” to municipal advisor registration, or any other regulation, undergo “a full
formal rulemaking” and be “appropriately communicated.” 144 As an example, this commenter stated
that the Commission recently updated the Registration of Municipal Advisors FAQs “without asking for
comment or industry input,” which, according to the commenter, has resulted in market participants
raising certain “interpretative questions” about new FAQs 2.3, 18.9, and 21.1. 145 As for potential areas

134

NAMA Letter, at 3.

135

NAMA Letter, at 3.

136

NAMA Letter, at 6.

137

NAMA Letter, at 6 (“Item 4 on Form MA calls for firms to ‘approximately’ list the number of MAs in their firm.
However, that can change by one or two throughout the year, and it is unclear if there is a requirement to amend the
Form when this happens. While we have relied on the term ‘approximately’ to accommodate minor changes, we were
questioned during an exam why our Form said X, and later in the year we had Y (off by one), and were noted for a
deficiency.”).

138

NAMA Letter, at 6 (“The maintenance of books and records has changed since the Rule was finalized. Instead of books
and records being printed and kept at a physical location, many firms utilize multiple cloud-based services to maintain
their books and records. Thus, a review of these questions related to location where books and records are kept should
be reviewed.”).

139

NAMA Letter, at 6.

140

NAMA Letter, at 6 (noting that Exchange Act Rule 15Ba1-8(a)(8) (17 CFR 240.15Ba1-8(a)(8)) “does not address the
exemptions for maintenance, and the documentation related to this section is confusing”).

141

NAMA Letter, at 6.

142

NAMA Letter, at 6.

143

SIFMA Letter, at 6.

144

SIFMA Letter, at 6.

145

SIFMA Letter, at 6; see also SIFMA Letter, at 6 (“For example, following the FAQs, further ambiguities exist as to
which ‘office’ an associated person should be assigned to on Form MA-I, if they regularly conduct business in that
office, but it isn’t one of the top five offices listed on the firm’s Form MA. Further, there are now industry questions
regarding new Registration of Municipal Advisors FAQ Question 2.3: Public-Private Partnerships – Considerations

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for clarification, this commenter stated that “[t]here remains a lack of clarity as to what constitutes a
solicitor municipal advisor, and we believe some firms may be registering as such merely out of an
abundance of caution and not because they are inten tionally engaging in solicitor municipal advisor
activity.” 146
After consideration, the Commission has not made any changes to its burden estimates based on
these comments. Nonetheless, staff agrees with many of the recommended areas for clarification. To
that end, staff intends to hold discussions with market participants to further develop the
recommendations, and to identify additional recommendations. Staff also intends to make public
statements clarifying certain areas that were the subject of these comments. With respect to the
comments concerning the Municipal Advisor FAQs, Commission staff emphasizes that staff statements
such as the Municipal Advisor FAQs and speeches by OMS staff are never intended to change existing
regulations, but rather are intended to share the staff’s current thinking on certain topics under the rules
as they currently exist. As always, OMS staff is open to discussing aspects of complying with the
municipal advisor registration rules that may be difficult for market participants, and would consider
updating staff statements such as the Municipal Advisor FAQs or providing further clarity should
market participants provide input post-publication.

9.

Payment or Gift to Respondents
Not applicable.

10.

Assurance of Confidentiality and Privacy

No assurances of confidentiality are provided, except with respect to certain private residential
addresses reported in Form MA and Form MA-I. Form MA and Form MA-I require applicants and
registered municipal advisors to report various addresses, which may include private residential
addresses. However, where the forms request an address, the applicant or registrant is asked to indicate
whether the address provided is a private residence and is advised that, if so, the private residential
address will not be included in publicly available versions of the form. To the extent the Commission
receives private residential addresses pursuant to submissions on Form MA and Form MA-I, and they are
indicated as such, such information would be kept confidential, subject to the provisions of applicable law
(e.g., Freedom of Information Act, 5 U.S.C. 552). Form MA and Form MA-I no longer request
applicants to submit SSNs, dates of birth, or foreign identity numbers effective May 14, 2018. 147
The information collection collects elements of PII that are covered by the EDGAR Privacy Impact
Assessment (“PIA”). 148 Additionally, the agency has determined that the information collection does not
constitute a system of records for purposes of the Privacy Act. Information is not retrieved by a personal
identifier.

Related to Responding to Requests and a new recordkeeping requirement created by Question 21.1: Recordkeeping
Requirement for Municipal Advisory Activities Relating to New Issue Pricing.”); SIFMA Letter, at 6 note 9 (“New FAQ
Question 2.3 does not mention the independent registered municipal advisor exemption, which has created industry
confusion.”).
146

SIFMA Letter, at 11.

147

See supra note 9 and accompanying text.

148

See EDGAR PIA (March 6, 2025), available at https://www.sec.gov/about/privacy/pia/pia-edgar.pdf. The PIA has been
included in the PRA submission to OMB.

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11.

Collection Questions of a Sensitive Nature
Not applicable.

12.

Estimated Time Burden and Its Cost Equivalent
a. Form MA: Application for Municipal Advisor Registration

The initial application for municipal advisor registration under Form MA is a one-time reporting
burden. The Commission estimates that this collection of information would apply to approximately 15
new municipal advisory firms that will submit new Form MA applications in each of the next three years. 149
This estimate is based on registration data for calendar years 2023, 2024, and 2025. Over the three years of
the information collection, the total estimated number of Form MA applicants would be 45, or 15 per
year.150 The Commission further estimates that the average amount of time for a municipal advisory firm to
complete Form MA would be approximately 3.5 hours. This figure is based on the estimated average
amount of time for a municipal advisory firm to complete Form MA and the estimated average amount of
time for an investment adviser to complete Part 1A of Form ADV. Thus, the Commission estimates that
the aggregate annual reporting burden placed on Form MA applicants will be approximately 53 hours.151
In addition to filing initial Form MA applications, the rules require municipal advisory firms to
amend Form MA once annually (Form MA-A) and after the occurrence of any enumerated material event
(Form MA/A). The requirement to amend Form MA is an ongoing annual reporting burden that applies to
all registered municipal advisory firms. As of December 31, 2025, there were approximately 419 municipal
advisors registered with the Commission and, as noted above, the Commission anticipates receiving 15 new
Form MA submissions annually in each of the next three years; however, the Commission also estimates
that it will receive an average of 21 withdrawals on Form MA-W annually in each of the next three years,152
and the Commission further estimates that it will enter orders cancelling or revoking the registration of 4
municipal advisors on average in each of the next three years, 153 for a net decrease of 10 municipal advisors
annually in each of the next three years.154 Therefore, the Commission expects that the rules’ requirement
to amend Form MA will apply to approximately 409 municipal advisors in year one, approximately 399
municipal advisors in year two, and approximately 389 municipal advisors in year three, or 399 respondents
on average.155 The Commission estimates that the average amount of time for a municipal advisor to
prepare an annual amendment to Form MA would be approximately 1.5 hours. The Commission further

149

The estimate is derived by averaging the number of Form MA filings over the last three years. There were 11 Form MA
submissions in 2023, 20 Form MA submissions in 2024, and 13 Form MA submissions in 2025.

150

15 (estimated number of Form MA applicants, year one) + 15 (estimated number of Form MA applicants, year two) + 15
(estimated number of Form MA applicants, year three) = 45.

151

15 (estimated number of Form MA applicants per year) x 3.5 hours (average time required to submit a completed Form
MA) = 52.5 hours.

152

See infra Section 12.c.

153

The estimate is derived by averaging the number of CANCELLATION-MA and REVOCATION-MA filings over the
last three years. There were 8 CANCELLATION-MA filings in 2023, 1 CANCELLATION-MA filing in 2024, and 1
CANCELLATION-MA filing in 2025. There were 0 REVOCATION-MA filings in 2023, 0 REVOCATION-MA
filings in 2024, and 0 REVOCATION-MA filings in 2025. ((8 + 0) + (1 + 0) + (1 + 0)) ÷ 3 = 3.33, rounded up to 4.

154

15 – (21 + 4) = -10.

155

(409 (year one) + 399 (year two) + 389 (year three)) ÷ 3 = 399.

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estimates that the average amount of time necessary to prepare any interim updating amendment to Form
MA other than the required annual amendment would be approximately 0.5 hours. This figure is based on
the burden estimates for an interim updating amendment for Form ADV. The Commission estimates that
each municipal advisor would likely submit two Form MA amendments annually in each of the next three
years – one annual amendment and one interim updating amendment. Thus, the Commission estimates that
the total annual reporting burden to amend Form MA would be approximately 818 hours in year one, 156 798
hours in year two, 157 and 778 hours in year three, 158 or approximately 2,394 hours over a three-year period.
The annual reporting burden per respondent to amend Form MA per year is 2.0 hours.
The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate)159 associated with the completion, amendment, and submission of Form MA is approximately
$271.160

156

((409 (number of municipal advisors required to submit an annual amendment to Form MA in year one) × 1.5 hours
(average estimated time to prepare an annual amendment to Form MA)) × 1.0 (number of annual amendments per year))
+ ((409 (number of municipal advisors required to submit an interim updating amendment to Form MA in year one) ×
0.5 hours (average estimated time to prepare an interim updating amendment to Form MA)) × 1.0 (number of interim
updating amendments per year)) = 818 hours.

157

((399 (number of municipal advisors required to submit an annual amendment to Form MA in year two) × 1.5 hours
(average estimated time to prepare an annual amendment to Form MA)) × 1.0 (number of annual amendments per year))
+ ((399 (number of municipal advisors required to submit an interim updating amendment to Form MA in year two) ×
0.5 hours (average estimated time to prepare an interim updating amendment to Form MA)) × 1.0 (number of interim
updating amendments per year)) = 798 hours.

158

((389 (number of municipal advisors required to submit an annual amendment to Form MA in year three) × 1.5 hours
(average estimated time to prepare an annual amendment to Form MA)) × 1.0 (number of annual amendments per year))
+ ((389 (number of municipal advisors required to submit an interim updating amendment to Form MA in year three) ×
0.5 hours (average estimated time to prepare an interim updating amendment to Form MA)) × 1.0 (number of interim
updating amendments per year)) = 778 hours.

159

To calculate the occupational hourly rates used in this Supporting Statement, the Commission uses occupational mean
hourly wage data from the Occupational Employment and Wage Statistics (“OEWS”) program of the Bureau of Labor
Statistics (“BLS”) for “Securities, Commodity Contracts, and Other Financial Investments and Related Activities”
(NAICS 523). See “Occupational Employment and Wage Statistics,” BLS, https://www.bls.gov/oes; see also “Standard
Occupational Classification,” BLS, https://www.bls.gov/soc (describing occupational classification system used by
BLS); Exec. Off. of the President, Off. of Mgmt. & Budget, North American Industry Classification System (2022),
available at https://www.census.gov/naics/reference_files_tools/2022_NAICS_Manual.pdf (describing the industry
classification system used by BLS and other agencies). The mean hourly wage for each occupation is adjusted for
changes in the seasonally adjusted employment cost index for private wages and salaries between the data reference
period and when the data are released by BLS. See “Employment Cost Index,” BLS, https://www.bls.gov/eci. The
adjusted mean hourly wage is then multiplied by a factor that accounts for nonwage costs borne by employers, such as
bonuses, benefits, and overhead. This factor is calculated as an average over the 10 most recently available years of data
of the ratio of the Bureau of Economic Analysis’s annual gross output data for NAICS 523 to total annual wages across
all occupations for NAICS 523 in the OEWS data. See “Gross Output by Industry,” U.S. Bureau of Economic Analysis,
https://www.bea.gov/data/industries/gross-output-by-industry; “Occupational Employment and Wage Statistics,” BLS,
https://www.bls.gov/oes. The final product is the occupational hourly rate. See generally “Updated Methodology for
Calculating Occupational Hourly Rates” (Dec. 19, 2025), available at https://www.sec.gov/files/method-occupationalhourly-rates.pdf.

160

This estimate uses a blended rate for Financial Examiners (SOC Code 13-2061) ($375/hour), and Bookkeeping,
Accounting, and Auditing Clerks (SOC Code 43-3031) ($167/hour). ($375/hour + $167/hour) ÷ 2 = $271/hour. See
generally BLS, OEWS, “13-2061 Financial Examiners,” https://www.bls.gov/oes/2023/may/oes132061.htm (“Enforce
or ensure compliance with laws and regulations governing financial and securities institutions and financial and real
estate transactions. May examine, verify, or authenticate records.”); BLS, OEWS, “43-3031 Bookkeeping, Accounting,
and Auditing Clerks,” https://www.bls.gov/oes/2019/may/oes433031.htm (“Compute, classify, and record numerical

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In summary, the Commission estimates that, over a three-year period, the total reporting
burden for the completion, amendment, and submission of Form MA would be 2,552 hours ($691,592
cost equivalent),161 or 851 hours ($230,621) per year when annualized over three years. The average
reporting burden per respondent would be approximately 6.40 hours ($1,734 cost equivalent),162 or
approximately 2.13 hours ($577) per year when annualized over three years.

b. Form MA-I: Information Regarding Natural Persons Who Engage in
Municipal Advisory Activities
The initial completion of Form MA-I for each natural person who is a person associated with a
municipal advisor is a one-time reporting burden. The Commission estimates that municipal advisors
would need to submit a new Form MA-I for approximately 370 individuals annually in each of the next
three years. 163 This estimate is based on existing MA-I submission data. Over the three years of the
information collection, the total estimated number of Form MA-I submissions would be approximately
1,110.164 The Commission further estimates that the average amount of time for a municipal advisory firm
to complete each Form MA-I would be approximately three hours. Accordingly, the Commission estimates
that respondents will spend approximately 3,330 hours completing Form MA-I over the three-year period.
The estimated average annual reporting burden per respondent to submit new Form MA-Is is approximately
2.89 hours.165
In addition, municipal advisory firms will need to complete amendments to Form MA-I (Form MAI/A) whenever the information previously provided therein becomes inaccurate, or to indicate that the
individual is no longer an associated person of the municipal advisor or no longer engages in municipal
advisory activities on its behalf. As discussed above, as of December 31, 2025, there were approximately
419 municipal advisors registered with the Commission, and the Commission estimates that approximately
45 firms will submit Form MA applications over the next three years. 166 These firms would need to prepare

data to keep financial records complete. Perform any combination of routine calculating, posting, and verifying duties to
obtain primary financial data for use in maintaining accounting records. May also check the accuracy of figures,
calculations, and postings pertaining to business transactions recorded by other workers. Excludes ‘Payroll and
Timekeeping Clerks’ (43-3051).”). The estimated additional cost burden to hire outside counsel and outside compliance
consultants to complete Form MA is reflected below in Section 13.a.
161

(45 (municipal advisory firms required to file Form MA, over three years) × 3.5 hours (average estimated time to
complete Form MA)) + 2,394 (total reporting burden to amend Form MA, over three years) = 2,551.5 hours.

162

2,552 (estimated average total burden to complete and amend Form MA, annually) ÷ 399 (estimated average number of
respondents annually) = 6.40 hours.

163

The estimate is derived by averaging the number of Form MA-I submissions over the last three years and rounding up.
There were 344 Form MA-I submissions in 2023, 385 Form MA-I submissions in 2024, and 379 Form MA-I
submissions in 2025. (344 (2023) + 385 (2024) + 379 (2025)) ÷ 3 = 369.33.

164

370 (estimated number of Form MA-I submissions, year one) + 370 (estimated number of Form MA-I submissions, year
two) + 370 (estimated number of Form MA-I submissions, year three) = 1,110.

165

((1,110 (estimated total burden to complete Form MA-I, year one) ÷ 370 (estimated number of respondents, year one)) +
(1,110 (estimated total burden to complete Form MA-I, year two) ÷ 385 (estimated number of respondents, year two)) +
(1,110 (estimated total burden to complete Form MA-I, year three) ÷ 400 (estimated number of respondents, year
three))) ÷ 3 = 2.89 hours.

166

See supra Section 12.a.

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amendments to Form MA-I for approximately 3,573 associated persons in year one, 167 3,943 associated
persons in year two, 168 and 4,313 associated persons in year three. 169 During calendar years 2023, 2024,
and 2025, municipal advisors submitted approximately 0.39 Form MA-I amendments for each Form MA-I
on file or, approximately, 1,232 Form MA-I amendments per year. 170 The Commission, however, expects
that firms will file an increasing number of Form MA-I amendments as the municipal advisor registration
regime continues to mature. As a result, the Commission estimates that a Form MA-I respondent would
submit an average of 2.91 amendments annually in each of the next three years, 171 and that each such
amendment would take approximately 0.5 hours to complete. Thus, the Commission estimates that the
total annual burden municipal advisors will incur to prepare amendments to Form MA-I would be
approximately 5,199 hours in year one,172 5,737 hours in year two,173 and 6,275 hours in year three,174 or
approximately 17,211 hours over a three-year period. This results in an estimated average annual
reporting burden of 14.41 hours per respondent. 175

167

3,203 (estimated number of active Form MA-I submissions on file with the Commission as of December 31, 2025) +
370 (estimated number of Form MA-I submissions, year one) = 3,573. The estimated number of active Form MA-I
filings is derived by taking the total number of Form MA-I submissions filed with the Commission from the inception of
the rules to December 31, 2025, and subtracting the total number of Form MA-I/A withdrawals filed with the
Commission from the inception of the rules to December 31, 2025. 9,596 (Form MA-I submissions) – 6,393 (Form MAI/A withdrawals) = 3,203 active Form MA-Is on file.

168

3,573 (estimated number of active MA-I submissions on file with the Commission after year one) + 370 (estimated
number of MA-I submissions, year two) = 3,943.

169

3,943 (estimated number of active Form MA-I submissions on file with the Commission after year two) + 370 (estimated
number of MA-I submissions, year three) = 4,313.

170

(1,234 (number of MA-I/As filed in 2023) + 1,043 (number of MA-I/As filed in 2024) + 1,419 (number of MA-I/As
filed in 2025)) ÷ 9,596 (estimated total number of MA-Is on file with the Commission as of December 31, 2025) = 0.39.
(1,234 (number of MA-I/As filed in 2023) + 1,043 (number of MA-I/As filed in 2024) + 1,419 (number of MA-I/As
filed in 2025)) ÷ 3 = 1,232.

171

The estimate is derived by averaging the number of amendments submitted by respondents over the last three years. In
2023, the average number was 1,234 Form MA-I/As ÷ 428 municipal advisors = 2.88. In 2024, the average number was
1,043 Form MA-I/As ÷ 425 municipal advisors = 2.45. In 2025, the average number was 1,419 Form MA-I/As ÷ 419
municipal advisors = 3.39. Averaging the average number of amendments for the last three years: (2.88 (2023) + 2.45
(2024) + 3.39 (2025)) ÷ 3 = 2.91 amendments per year.

172

(3,573 (estimated number of associated persons for whom amendments to Form MA-I would need to be filed, year one)
× 2.91 (average number of amendments per year)) x (0.50 hours (average estimated time to prepare an amendment to
Form MA-I)) = 5,198.72 hours per year.

173

(3,943 (estimated number of associated persons for whom amendments to Form MA-I would need to be filed, year two)
× 2.91 (average number of amendments per year)) x (0.50 hours (average estimated time to prepare an amendment to
Form MA-I)) = 5,737.07 hours per year.

174

(4,313 (estimated number of associated persons for whom amendments to Form MA-I would need to be filed, year three)
× 2.91 (average number of amendments per year)) x (0.50 hours (average estimated time to prepare an amendment to
Form MA-I)) = 6,275.42 hours per year.

175

((5,199 hours (estimated total annual reporting burden for Form MA-I amendments, year one) ÷ 409 (estimated number
of respondents required to amend Form MA-I, year one)) + (5,737 (estimated total annual reporting burden for Form
MA-I amendments, year two) ÷ 399 (estimated number of respondents required to amend Form MA-I, year two)) +
(6,275 (estimated total annual reporting burden for Form MA-I amendments, year three) ÷ 389 (estimated number of
respondents required to amend Form MA-I, year three))) ÷ 3 = 14.41 hours.

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The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate) associated with the completion, amendment, and submission of Form MA-I is approximately
$271.176
In summary, the Commission estimates that, over a three-year period, the total reporting
burden for the completion, amendment, and submission of Form MA-I would be 20,541 hours ($5.6
million cost equivalent),177 or 6,847 hours ($1.9 million) per year when annualized over three years.
The average reporting burden per respondent would be approximately 51.48 hours ($13,951 cost
equivalent),178 or approximately 17.16 hours ($4,650) per year when annualized over three years.

c. Form MA-W: Notice of Withdrawal from Registration as a Municipal
Advisor
Withdrawal from municipal advisor registration is a one-time reporting burden. The Commission
estimates that there would be approximately 21 withdrawals from Form MA registration annually in each of
the next three years. 179 Over the three years of the information collection, the total estimated number of
Form MA-W submissions would be 63.180
The Commission further estimates that the average amount of time for a municipal advisor to
complete each Form MA-W submission would be approximately 0.5 hours.
The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate) associated with the completion of Form MA-W is approximately $271. 181
In summary, the Commission estimates that, over a three-year period, the total one-time
reporting burden for the completion of Form MA-W would be 31.5 hours ($8,537 cost equivalent),182
or approximately 10.5 hours ($2,846) per year when annualized over three years. The one-time
reporting burden would be 0.5 hours ($136) per respondent. 183

176

See supra notes 160-161.

177

3,330 (estimated total burden to complete and file Form MA-Is during three-year period) + 17,211 (estimated total
burden to complete and file Form MA-I amendments during three-year period) = 20,541 hours.

178

20,541 hours (average annual total burden to complete and amend Form MA-I, over three years) ÷ 399 (average number
of respondents, over three years) = 51.48 hours.

179

The estimate of 21 Form MA-W submissions is derived by averaging the number of Form MA-W submissions over the
last three years and rounding up. There were 21 Form MA-W submissions in 2023, 22 Form MA-W submissions in
2024, and 18 Form MA-W submissions in 2025.

180

21 (estimated number of Form MA-W submissions, year one) + 21 (estimated number of Form MA-W submissions,
year two) + 21 (estimated number of Form MA-W submissions, year three) = 63.

181

See supra notes 160-161.

182

63 (estimated number of Form MA-W submissions, over three years) × 0.5 hours (average estimated time to complete
Form MA-W) = 31.5 hours.

183

31.5 hours (total burden to complete Form MA-W, over three years) ÷ 63 (total number of MA-W submissions, over
three years) = 0.5 hours.

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d. Form MA-NR: Designation of U.S. Agent for Service of Process for
Non-Residents
The designation of a U.S. agent for service of process is a one -time reporting burden. The
Commission estimates that approximately four municipal advisors will have a non-resident general partner,
non-resident managing agent, or non-resident associated person184 and such advisors will submit a total of
approximately seven Form MA-NRs annually in each of the next three years. 185 These estimates are based
on existing municipal advisor registration data. Over three years, the four non-resident municipal advisor
respondents would file approximately 21 Form MA-NRs.186
The Commission further estimates that the average amount of time to complete each Form MA-NR
would be approximately one hour. This figure is based on the burden estimates for completing Form ADVNR. Thus, the Commission estimates that the total annual burden to complete Form MA-NR would be
approximately 28 hours,187 or approximately 7 hours per respondent annually. 188
In addition, each respondent that submits a Form MA-NR must also provide an opinion of
counsel on Form MA stating that the municipal advisor can, as a matter of law, provide the Commission
with access to its books and records as required by law and submit to inspection and examination by the
Commission. The Commission estimates that such an opinion of counsel would take three hours to
complete. Thus, the Commission estimates that the total annual burden to provide the opinions of
counsel would be approximately 12 hours, or 36 hours over the three-year period. 189
The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate) associated with the completion of Form MA-NR is approximately $271. 190
In summary, the Commission estimates that, over a three-year period, the total reporting
burden for the completion of Form MA-NR would be approximately 64 hours ($17,344 cost
equivalent),191 or approximately 21.3 hours ($5,772) per year when annualized over three years. The

184

The estimate is derived by averaging the number of Form MA-NR respondents over the last three years and rounding up.
There were three Form MA-NR respondents in 2023, two Form MA-NR respondent in 2024, and six Form MA-NR
respondents in 2025.

185

The estimate is derived by averaging the number of Form MA-NR submissions over the last three years and rounding
up. There were six Form MA-NR submissions in 2023, six Form MA-NR submissions in 2024, and eight Form MA-NR
submissions in 2025.

186

7 (estimated number of Form MA-NR submissions, year one) + 7 (estimated number of Form MA-NR submissions, year
two) + 7 (estimated number of Form MA-NR submissions, year three) = 21.

187

(7 (estimated Form MA-NR submissions each year) × 4 (estimated number of respondents each year)) x 1 hour (average
estimated time to complete Form MA-NR) = 28 hours.

188

28 hours (estimated total annual burden to complete and file Form MA-NRs) ÷ 4 (estimated number of respondents,
annually) = 7 hours.

189

4 (non-resident municipal advisory firms expected to provide opinion of counsel, annually) × 3.0 hours (average
estimated time to provide an opinion of counsel) = 12 hours.

190

See supra notes 160-161. The estimated additional cost burden to hire outside counsel as part of providing an opinion of
counsel is reflected below in Section 13.d.

191

28 hours (total burden to complete Form MA-NR) + 36 hours (total burden to provide opinions of counsel) = 64 hours.

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reporting burden per respondent would be approximately 16 hours ($4,336 cost equivalent),192 or
approximately 5.3 hours ($1,436) per year when annualized over three years.

e. Consent to Service of Process from Certain Associated Persons
The consent to service of process from certain associated persons is a one -time recordkeeping
burden. Over three years, the Commission estimates that all 45 new municipal advisory firms expected
to register with the Commission over the next three years will need to complete a written consent to
service of process from each natural person engaged in municipal advisory activities on their behalf. 193
The Commission further estimates that each municipal advisory firm would spend approximately one
hour to draft a template document to use in obtaining the written consents to service of process,
amounting to an initial, one-time burden of approximately 45 hours over three years,194 or 15 hours per
year.
In addition to the one-time burden borne by new municipal advisory firms that register with the
Commission during the three-year period, the Commission estimates that existing municipal advisory
firms would need to obtain 370 consents to service of process from natural persons that begin engaging
in municipal advisory activities on their behalf in each of the next three years. The Commission further
estimates that, after the written consents are drafted, it will take municipal advisory firms approximately
0.10 hours to obtain each consent. Thus, the Commission estimates that municipal advisory firms would
spend approximately 111 hours over the three-year period obtaining written consents from their
associated persons,195 or 37 hours per year. Based on existing registration data, the Commission
estimates that approximately 35 of the 111 hours municipal advisory firms will spend obtaining written
consents will be borne by newly registered firms, while approximately 76 of such hours will be borne by
municipal advisory firms currently registered with the Commission. 196

192

64 hours (estimated total burden to complete Form MA-NR and opinion of counsel, over three years) ÷ 4 (estimated
number of non-resident municipal advisory firms) = 16 hours.

193

Rule 15Ba1-8(a)(8) requires each municipal advisory firm to retain written consents to service of process from each
natural person who is a person associated with the municipal advisor and engages in municipal advisory activities solely
on behalf of such registered municipal advisor.

194

45 (estimated number of applicants for municipal advisor registration over the three-year period) × 1.0 hour (estimated
time required to draft a template to use in obtaining the written consents to service of process) = 45 hours.

195

(370 (estimated number of Form MA-I submissions, year one) + 370 (estimated number of Form MA-I submissions,
year two) + 370 (estimated number of Form MA-I submissions, year three)) × 0.10 hours (estimated time required to
obtain the written consents to service of process) = 111 hours.

196

Current registration data indicate that the average number of associated persons per municipal advisory firm is
approximately 7.64 (3,203 (estimated number of active Form MA-I submissions on file with the Commission as of
December 31, 2025) ÷ 419 (estimated number of municipal advisors registered with the Commission as of December 31,
2025) = 7.64). Accordingly, based on the Commission’s assumption that it will receive 15 new Form MA applications
per year over the three-year period, those new applicants will also submit approximately 115 new Form MA-Is per year
over the three-year period (15 new Form MA applications, annually) x 7.64 (average number of associated persons per
municipal advisory firm) = 114.6.
(115 (estimated number of Form MA-I submissions by new registrants, year 1) + 115 (estimated number of Form MA-I
submission by new registrants, year 2) + 115 (estimated number of Form MA-I submissions by new registrants, year 3))
x 0.10 hours (estimated time required to obtain the written consents to service of process) = 34.5 hours.

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The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate) associated with obtaining written consents to service of process is approximately $271. 197
In summary, the Commission estimates that, over a three-year period, the total
recordkeeping burden for all municipal advisory firms to obtain written consents to service of
process from each natural person engaged in municipal advisory activities on their behalf would
be 156 hours ($42,276 cost equivalent),198 or 52 hours ($14,092) per year when annualized over
three years. The recordkeeping burden per respondent would be approximately 0.39 hours ($106
cost equivalent),199 or approximately 0.13 hours ($35) per year when annualized over three years.

f. Rule 15Ba1-8: Books and Records to Be Made and Maintained by
Municipal Advisors
The maintenance of books and records is an ongoing annual recordkeeping burden. The
Commission estimates that this collection of information currently applies to approximately 419 municipal
advisory firms, and further estimates that it will apply to approximately 409, 399, and 389 municipal
advisors annually in each of the next three years, respectively. 200
The Commission further estimates that the average annual burden for a municipal advisory firm
to comply with the recordkeeping requirements would be approximately 182 hours. Thus, the
Commission estimates that the total ongoing recordkeeping burden for th e three-year period would be
217,854 hours.201 The estimated annual recordkeeping burden over the three-year period would be
74,438 hours in year one;202 72,618 hours in year two;203 and 70,798 in year three. 204

197

See supra notes 160-161.

198

Total estimated annual burden: 15 hours (one-time burden to draft template document) + 37 hours (ongoing burden to
obtain consent) = 52 hours. 52 hours (estimated burden for all municipal advisory firms to obtain written consents to
service of process from each natural person engaged in municipal advisory activities on their behalf, year one) + 52
hours (estimated burden to obtain written consents to service of process from each natural person engaged in municipal
advisory activities on their behalf, year two) + 52 hours (estimated burden to obtain written consents to service of
process from each natural person engaged in municipal advisory activities on their behalf, year three) = 156 hours.

199

156 hours (total estimated annual burden for all municipal advisory firms to obtain written consents to service of process
from each natural person engaged in municipal advisory activities on their behalf, during the three-year period) ÷ 399
(estimated average number of registered municipal advisory firms, during the three-year period) = 0.391 hours.

200

See supra Section 12.a.

201

(409 (estimated number of municipal advisors after year one) × 182 hours (estimated time spent by municipal advisors to
ensure annual compliance with the books and records requirement)) + 399 (estimated number of municipal advisors after
year two) x 182 hours (estimated time spent by municipal advisors to ensure annual compliance with books and records
requirement)) + 389 (estimated number of municipal advisors after year three) x 182 hours (estimated time spent by
municipal advisors to ensure annual compliance with books and records requirement)) = 217,854 hours.

202

(409 (estimated number of municipal advisors after year one) x 182 hours (estimated time spent by municipal advisors to
ensure annual compliance with the books and records requirement) = 74,438 hours.

203

(399 (estimated number of municipal advisors after year two) x 182 hours (estimated time spent by municipal advisors to
ensure annual compliance with the books and records requirement) = 72,618 hours.

204

(389 (estimated number of municipal advisors after year three) x 182 hours (estimated time spent by municipal advisors
to ensure annual compliance with the books and records requirement) = 70,798 hours.

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The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate) associated with this recordkeeping burden is approximately $271. 205
In summary, the Commission estimates that, over a three-year period, the total
recordkeeping burden would be 217,854 hours ($59 million cost equivalent),206 or 72,618 hours
($19.7 million) when annualized over three years. The estimated annual recordkeeping burden per
respondent would be 182 hours ($49,322).

g. Rule 15Ba1-1(d)(3)(vi): Exemption When a Municipal Entity or
Obligated Person Is Represented by an Independent Registered
Municipal Advisor
The written representations required pursuant to the exemption when a municipal entity or
obligated person is represented by an independent registered municipal advisor is a one -time third-party
disclosure burden. The Commission estimates that this collection of information would apply to
approximately 157 respondents annually in each of the next three years. 207 The Commission further
estimates that each respondent seeking to rely on this exemption would need approximately one hour to
draft a template document to use in obtaining the written representation, amounting to an initial, one time burden of approximately 157 hours.208
The Commission also recognizes that respondents will be subject to a recurring burden each time
they seek to rely on this exemption. The Commission estimates that respondents may seek the
exemption on approximately 12,381 transactions annually in each of the next three years. 209 The
Commission further estimates that a person seeking to rely on this exemption would need approximately
0.25 hours to obtain a written representation from a municipal entity or obligated person, amounting to
an annual ongoing burden of approximately 3,095.25 hours,210 or 9,286 hours over the three-year period.
The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate) related to the exemption when a municipal entity or obligated person is represented by an

205

See supra notes 160-161.

206

See supra note 202 and accompanying text.

207

Estimate based on information obtained from Mergent Municipal Bond Securities Database. The estimate is derived by
averaging the number of underwriters that participated in negotiated transactions from 2023 to 2025. There were 158
underwriters that participated in negotiated transactions in 2023, 160 underwriters that participated in negotiated
transactions in 2024, and 153 underwriters that participated in negotiated transactions in 2025.

208

157 (estimated number of respondents that will seek to rely on the exemption) × 1.0 hours (estimated time required to
draft the written representation) = 157 hours. The Commission believes that once these disclosures have been drafted,
such language would become part of the standard municipal advice documentation and, accordingly, there would be no
further ongoing associated burden.

209

Estimate based on information obtained from Mergent Municipal Bond Securities Database. The estimate is derived by
averaging the number of negotiated deals using an underwriter each year from 2023 to 2025 and rounding up. There
were 11,825 negotiated deals using an underwriter in 2023, 12,545 negotiated deals using an underwriter in 2024, and
12,771 negotiated deals using an underwriter in 2025.

210

12,381 (estimated average number of negotiated deals per year) × 0.25 hours (estimated time required to obtain the
written representation) = 3,095.25 hours.

U.S. Securities and Exchange Commission (SEC)
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independent registered municipal advisor is approximately $271. 211
In summary, the Commission estimates that, over a three-year period, the total one-time
third-party disclosure burden related to the exemption when a municipal entity or obligated
person is represented by an independent registered municipal advisor would be 9,443 hours ($2.6
million cost equivalent),212 or 3,148 hours ($853,108) per year when annualized over three years.
The third-party disclosure burden per respondent would be approximately 60.15 hours ($16,300 cost
equivalent),213 or 20.05 hours ($5,434) per year when annualized over three years.

h. Rule 15Ba1-1(h)(2): Exception to Definition of Municipal Escrow
Investments
The written representations required to qualify for the exception for reasonable reliance on
representations related to municipal escrow investments is a one-time third-party disclosure burden. The
Commission believes that state-registered investment advisers with municipal entity clients are the
persons most likely to rely on this exception. The Commission estimates that approximately 611
persons may seek to rely on this exception. 214
The Commission further estimates that each person seeking to rely on this exception would need
approximately one hour to draft a template document to use in obtaining the written representation,
amounting to an initial, one-time burden of approximately 611 hours.215 In addition, the Commission
estimates that, once drafted, a person seeking to rely on this exception would need approximately 0.25
hours to obtain a written representation from its client each time they seek to rely on the exception.
Based on responses to Form ADV, the Commission estimates that persons that would seek to rely on
this exception have approximately 1,855 clients that are municipal entities. 216 Thus, the Commission
estimates that the burden to obtain the written representation would be 471 hours.217
The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate) associated with the exception for reasonable reliance on representations related to municipal

211

See supra notes 160-161.

212

(157 hours (estimated time to draft a template document to use in obtaining the written representation, year one) + 9,286
hours (estimated time to obtain a written representation from a municipal entity or obligated person, three-year period) =
9,443 hours.

213

9,443 hours (total burden related to the exemption when a municipal entity or obligated person is represented by an
independent registered municipal advisor, over three years) ÷ 157 (estimated number of persons who will seek to rely on
the exemption) = 60.15 hours.

214

The Commission estimates in this section are based on information reported directly by state-registered-only investment
advisers (i.e., not dual registrants) in Item 5.D.(i)(1) within Form ADV, as of December 31, 2025. The number of stateregistered investment advisers that reported state or municipal government entity clients in Item 5.D.(i)(1) within Form
ADV = 611.

215

611 (estimated number of persons who will seek to rely on the exception) × 1.0 hours (estimated time required to draft
the written representation) = 611 hours.

216

The number of state or municipal government entity clients reported by state-registered investment advisers in Item
5.D.(i)(1) within Form ADV = 1,885.

217

1,885 (estimated number of clients from which written representation will be obtained) × 0.25 hours (estimated time
required to obtain the written representation) = 471.25 hours.

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escrow investments is approximately $271. 218
In summary, the Commission estimates that, over a three-year period, the one-time total
third-party disclosure burden for all persons to rely on the exception for reasonable reliance on
representations related to municipal escrow investments would be 1,082 hours ($293,222 cost
equivalent),219 or 361 hours ($97,831) per year when annualized over three years. The one-time
third-party disclosure burden per respondent would be approximately 1.77 hours ($480 cost
equivalent),220 or approximately 0.59 hours ($160) per year when annualized over three years.

i. Rule 15Ba1-1(m)(3): Exception to Definition of Proceeds of Municipal
Securities
The written representations required to qualify for the exception for reasonable reliance on
representations related to proceeds of municipal securities is a one-time third-party disclosure burden.
The Commission believes the persons most likely to rely on this exception are state-registered
investment advisers with clients that are: (i) state or municipal government entities, or (ii) certain pooled
investment vehicles in which municipal entities invest. Based on responses to Form ADV, the
Commission estimates that approximately 669 persons may seek to rely on this exception. 221
The Commission further estimates that each person seeking to rely on this exception would need
approximately one hour to draft a template document to use in obtaining the written representation,
amounting to an initial, one-time burden of approximately 669 hours.222 In addition, the Commission
estimates that, once drafted, a person seeking to rely on this exception would need approximately 0.25
hours to obtain a written representation from its client each time they seek to rely on the exception.
Based on responses to Form ADV, the Commission estimates that persons that would seek to rely on
this exception have approximately 3,326 clients that are state or municipal government entities or that
are pooled investment vehicles (other than registered investment companies and business development
companies) with municipal entity investors. 223 Thus, the Commission estimates that the burden to

218

See supra notes 160-161.

219

611 hours (estimated time to draft a template document to use in obtaining the written representation, over three years) +
471 hours (estimated time required to obtain the written representations from clients, over three years) = 1,082 hours.

220

1,082 hours (total burden related to the exception for reasonable reliance on representations related to municipal escrow
investments, during the three-year period) ÷ 611 (estimated number of persons who will seek to rely on the exception,
during the three-year period) = 1.77 hours.

221

The Commission estimates in this section are based on information reported directly by state-registered-only investment
advisers (i.e., not dual registrants) in Items 5.D.(i)(1) and 5.D.(f)(1) within Form ADV, as of December 31, 2025. The
number of state-registered investment advisers that reported pooled investment vehicle clients (other than investment
company and business development company clients) in Item 5.D.(f)(1) within Form ADV = 480. The percentage of
state-registered investment advisers that reported state or municipal government entity clients in Item 5.D.(f)(1) within
Form ADV, out of the total number of state-registered investment advisers = 12%. (480 x .12) = approximately 58 stateregistered investment advisers with clients that are pooled investment vehicles (other than registered investment
companies and business development companies) in which municipal entities invest. The number of state-registered
investment advisers that reported state or municipal government entity clients in Item 5.D.(i)(1) within Form ADV =
611. (58 + 611) = 669 respondents.

222

669 (estimated number of respondents that will seek to rely on the exception) × 1.0 hours (estimated time required to
draft the written representation) = 669 hours.

223

The number of state or municipal government entity clients reported by state-registered investment advisers in Item
5.D.(i)(1) within Form ADV = 1,885 clients. The number of pooled investment vehicle clients (other than investment

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obtain the written representation would be 832 hours.224
The Commission estimates that the average internal cost of compliance per hour (occupational
hourly rate) associated with the exception for reasonable reliance on representations related to proceeds
of municipal securities is approximately $271. 225
In summary, the Commission estimates that, over a three-year period, the total one-time
third-party disclosure burden for all persons to rely on the exception for reasonable reliance on
representations related to proceeds of municipal securities would be 1,501 hours ($406,771 cost
equivalent),226 or 500.33 hours ($135,589) per year when annualized over three years. The one-time
third-party disclosure burden per respondent would be approximately 2.24 hours ($607),227 or
approximately 0.75 hours ($203) per year when annualized over three years.

j. Summary of Hourly Burdens
The table below summarizes the Commission’s estimates of the total hourly burdens for all
respondents under the rules and forms.228

Information Collections (ICs)
Form MA: Application for Municipal
Advisor Registration
Form MA-I: Information Regarding Natural
Persons Who Engage in Municipal Advisory
Activities
Form MA-W: Notice of Withdrawal from
Registration as a Municipal Advisor
Form MA-NR: Designation of U.S. Agent
for Service of Process for Non-Residents
Consent to Service of Process from Certain
Associated Persons
Rule 15Ba1-8: Books and Records to Be
Made and Maintained by Municipal
Advisors

Requirement
Type

Number of
Respondents

Total Annual
Time Burden
(Hours)

Total Annual
Cost Burden
Equivalent ($)

Reporting

399

851

$230,621

Reporting

399

6,847

$1.9 million

Reporting

21

10.5

$2,846

Reporting

4

21.3

$5,772

Recordkeeping

399

52

$14,092

Recordkeeping

399

72,618

$19.7 million

company and business development company clients) reported by state-registered investment advisers in Item 5.D.(f)(1)
within Form ADV = 1,441 clients. (1,885 + 1,441) = 3,326 clients.
224

3,326 (estimated number of clients from which written representation will be obtained) × 0.25 hours (estimated time
required to obtain the written representation) = approximately 832 hours.

225

See supra notes 160-161.

226

669 hours (estimated time to draft a template document to use in obtaining the written representation, during the threeyear period) + 832 hours (estimated time required to obtain the written representations from clients, during the three-year
period) = 1,501 hours.

227

1,501 hours (total burden related to the exception for reasonable reliance on representations related to proceeds of
municipal securities, over three years) ÷ 669 (estimated number of persons who will seek to rely on the exception, over
three years) = 2.24 hours.

228

Numbers may not foot due to rounding.

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Rule 15Ba1-1(d)(3)(vi): Exemption When a
Municipal Entity or Obligated Person Is
Represented by an Independent Registered
Municipal Advisor
Rule 15Ba1-1(h)(2): Exception to Definition
of Municipal Escrow Investments
Rule 15Ba1-1(m)(3): Exception to Definition
of Proceeds of Municipal Securities

Third-Party
Disclosure
Third-Party
Disclosure
Third-Party
Disclosure

TOTAL ICs: 9

13.

157

3,148

$853,108

611

361

$97,831

669

500.33

$135,589

ICR TOTAL:

84,409 Hours

$22.9 million

Estimated Additional Cost Burden
a. Form MA: Application for Municipal Advisor Registration

The Commission believes that some municipal advisory firms would seek outside counsel or
outside compliance consultants to help them comply with the requirements of the final rules and to
complete Form MA. For PRA purposes, the Commission assumes that all 45 municipal advisory firms
registering on Form MA during the three-year period would, on average, consult with outside counsel or
outside compliance consultants for one hour, and would cost $25,875 for all municipal advisory firms.229
In summary, the Commission estimates that, over a three-year period, the total additional
cost burden for all municipal advisory firms to hire outside counsel and outside compliance
consultants to complete Form MA would be approximately $25,875,230 or $8,625 per year when
annualized over three years. The total additional cost burden per respondent would be
approximately $575,231 or approximately $191.67 when annualized over three years.

b. Form MA-I: Information Regarding Natural Persons Who Engage in
Municipal Advisory Activities
Not applicable. The Commission does not anticipate that respondents will incur any costs in
completing Form MA-I other than the internal compliance costs identified above in Section 12.

c. Form MA-W: Notice of Withdrawal from Registration as a Municipal
Advisor
Not applicable. The Commission does not anticipate that respondents will incur any costs in
completing Form MA-W other than the internal compliance costs identified above in Section 12.

229

45 (estimated number of municipal advisory firms that would hire outside counsel or outside compliance consultants,
over three years) × 1 hour (average estimated time spent by outside counsel to help a municipal advisory firm comply
with the rule) × $575 (estimated blended average hourly rate for an outside attorney and outside compliance consultant)
= $25,875. The hourly cost estimate of $575 uses a blended rate for Lawyers (SOC Code 23-1011) ($774/hour), and
Financial Examiners (SOC Code 13-2061) ($375/hour). ($774/hour + $375/hour) ÷ 2 = $574.5/hour, rounded up. See
generally supra note 160.

230

See id.

231

$25,875 (total additional cost burden to hire outside counsel and outside compliance consultants, over three years) ÷ 45
(estimated number of municipal advisory firms that would hire outside counsel, over three years) = $575.

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d. Form MA-NR: Designation of U.S. Agent for Service of Process for
Non-Residents
The Commission believes that non-resident municipal advisors would seek outside counsel to
comply with the opinion of counsel requirements of Form MA-NR. The Commission estimates that this
would add $1,584 in outside legal costs per respondent. 232 Thus, the Commission estimates that the total
annual cost for all non-resident municipal advisory firms to hire outside counsel as part of providing an
opinion of counsel would be $6,336,233 or $19,008 over the three-year period.
In summary, the Commission estimates that, over a three-year period, the total cost for all
non-resident municipal advisory firms to hire outside counsel as part of providing an opinion of
counsel would be approximately $19,008,234 or $6,336 per year when annualized over three years.
The total additional cost burden per respondent would be $4,752,235 or $1,584 per year when
annualized over three years.

e. Consent to Service of Process from Certain Associated Persons
Not applicable. The Commission does not anticipate that respondents will incur any costs to
comply with this requirement other than the internal compliance costs identified above in Section 12 .

f. Rule 15Ba1-8: Books and Records to Be Made and Maintained by
Municipal Advisors
Not applicable. The Commission does not anticipate that respondents will incur any costs to
comply with this requirement other than the internal compliance costs identified above in Section 12 .

g. Rule 15Ba1-1(d)(3)(vi): Exemption When a Municipal Entity or
Obligated Person Is Represented by an Independent Registered
Municipal Advisor
Not applicable. The Commission does not anticipate that respondents will incur any costs to utilize
this exemption other than the internal compliance costs identified above in Section 12 .

h. Rule 15Ba1-1(h)(2): Exception to Definition of Municipal Escrow
Investments
Not applicable. The Commission does not anticipate that respondents will incur any costs to

232

The $1,584 figure is based on an hourly cost estimate of $528 on average for outside counsel and three hours of work.
Based on previous burden estimates, the Commission estimated that outside counsel will take, on average, three hours to
assist in preparation of the opinion of counsel, for an average cost of $1,584 per respondent. The hourly cost estimate of
$528 uses a blended rate for Lawyers (SOC Code 23-1011) ($774/hour), and Paralegals and Legal Assistants (SOC Code
23-2011) ($281/hour). ($774/hour + $281/hour) ÷ 2 = $527.5/hour, rounded up. See generally supra note 160.

233

4 (non-resident municipal advisory firms expected to provide opinion of counsel, annually) × $1,584 (average estimated
cost to hire outside counsel to provide an opinion of counsel) = $6,336.

234

$6,336 (estimated total annual cost for respondents to provide opinions of counsel) x 3 (number of years) = $19,008.

235

$19,008 (total additional cost burden to hire outside counsel as part of providing an opinion of counsel, during the threeyear period) ÷ 4 (total number of non-resident municipal advisory firms providing an opinion of counsel, during the
three-year period) = $4,752.

U.S. Securities and Exchange Commission (SEC)
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qualify for this exception other than the internal compliance costs identified above in Section 12 .

i. Rule 15Ba1-1(m)(3): Exception to Definition of Proceeds of Municipal
Securities
Not applicable. The Commission does not anticipate that respondents will incur any costs to
qualify for this exception other than the internal compliance costs identified above in Section 12 .

j. Summary of Cost Burdens
The table below summarizes the Commission’s estimates of the additional cost burdens for
respondents under the rules and forms.
Additional Information Collections
(ICs)
Form MA - Additional Cost Burdens
Form MA-NR - Additional Cost
Burdens

Related Supporting Statement
Question 12 IC
Form MA: Application for Municipal
Advisor Registration
Form MA-NR: Designation of U.S.
Agent for Service of Process for NonResidents

TOTAL ICs: 2

14.

Requirement
Type

Total Annual
Additional
Cost Burden
($)

Reporting

$8,625

Reporting

$6,336

ICR TOTAL:

$14,961

Annual Cost to the Federal Government

The SEC is in the process of revising its methodologies to estimate annualized costs to the Federal
government for all its relevant collections of information. The SEC anticipates that future extensions of this
collection of information will reflect the revised methodologies.

15.

Reasons for Changes in Burden Estimates

The table below summarizes the Commission’s reasons for any program changes or adjustments
reported on the burden worksheet. As summarized below, adjustments in estimates are based on recent
three year averages of collection activities. In addition, cost equivalent estimates were added to each
information collection to reflect internal costs of compliance; cost equivalent estimates and additional
cost burdens were calculated using the Commission’s Updated Methodology for Calculating
Occupational Hourly Rates (“Updated Methodology”), https://www.sec.gov/files/method-occupationalhourly-rates.pdf, published December 19, 2025; the cost burdens to complete Form MA-NR now reflect
the estimated cost equivalent rather than the estimated additional cost burdens; and a new information
collection estimating the additional cost burdens to complete Form MA-NR was added.
Information Collections (ICs)

Area of Change

Form MA: Application for Municipal
No. of Responses
Advisor Registration

U.S. Securities and Exchange Commission (SEC)
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Reason for Change in Burden Estimates
Change Due to Adjustment in Agency Estimate –
Increased from 388 to 399 based upon data
obtained since the prior PRA renewal process in
2023.

Information Collections (ICs)

Area of Change

Time Burden (Hours)

Cost Burden ($)

Form MA - Additional Cost Burdens

Cost Burden ($)

No. of Responses

Form MA-I: Information Regarding
Time Burden (Hours)
Natural Persons Who Engage in
Municipal Advisory Activities
Cost Burden ($)

No. of Responses
Form MA-W: Notice of Withdrawal Time Burden (Hours)
from Registration as a Municipal
Advisor
Cost Burden ($)

No. of Responses

Form MA-NR: Designation of U.S.
Agent for Service of Process for
Non-Residents

Time Burden (Hours)

Cost Burden ($)

236

Reason for Change in Burden Estimates
Change Due to Adjustment in Agency Estimate –
Increased from 829 to 851 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Added cost equivalent estimate for this information
collection. Increased from $0 to $230,621 after
considering internal costs of compliance under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Increased from $7,770 to $8,625 under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Increased from 388 to 399 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Increased from 5,667 to 6,847 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Added cost equivalent estimate for this information
collection. Increased from $0 to $1,855,537 after
considering internal costs of compliance under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Decreased from 35 to 21 based upon data obtained
since the prior PRA renewal process in 2023.
Change Due to Adjustment in Agency Estimate –
Decreased from 18 to 11 based upon data obtained
since the prior PRA renewal process in 2023.
Change Due to Adjustment in Agency Estimate –
Added cost equivalent estimate for this information
collection. Increased from $0 to $2,846 after
considering internal costs of compliance under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Increased from 9 to 21 based upon data obtained
since the prior PRA renewal process in 2023.
Change Due to Adjustment in Agency Estimate –
Increased from 14 236 to 21 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Changed cost burden for this information collection
to reflect cost equivalent rather than additional cost
burdens. Increased from $4,662 to $5,772 under
the Commission’s Updated Methodology.

The previously approved estimate of 14 hours appears to have been based on an erroneous calculation that led to more
hours being requested than necessary.

U.S. Securities and Exchange Commission (SEC)
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Information Collections (ICs)

Form MA-NR - Additional Cost
Burdens

Area of Change

Cost Burden ($)

No. of Responses

Consent to Service of Process from
Certain Associated Persons

Time Burden (Hours)

Cost Burden ($)

No. of Responses

Rule 15Ba1-8: Books and Records to
Time Burden (Hours)
Be Made and Maintained by
Municipal Advisors
Cost Burden ($)

No. of Responses
Rule 15Ba1-1(d)(3)(vi): Exemption
When a Municipal Entity or Obligated
Time Burden (Hours)
Person Is Represented by an
Independent Registered Municipal
Advisor
Cost Burden ($)

No. of Responses
Rule 15Ba1-1(h)(2): Exception to
Definition of Municipal Escrow
Investments
Time Burden (Hours)

U.S. Securities and Exchange Commission (SEC)
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Reason for Change in Burden Estimates
Change Due to Adjustment in Agency Estimate –
New information collection reflecting additional
cost burdens. Estimated $6,336 under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Increased from 388 to 399 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Increased from 48 to 52 based upon data obtained
since the prior PRA renewal process in 2023.
Change Due to Adjustment in Agency Estimate –
Added cost equivalent estimate for this information
collection. Increased from $0 to $14,092 after
considering internal costs of compliance under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Increased from 388 to 399 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Increased from 70,616 to 72,618 based upon data
obtained since the prior PRA renewal process in
2023..
Change Due to Adjustment in Agency Estimate –
Added cost equivalent estimate for this information
collection. Increased from $0 to $19,679,478 after
considering internal costs of compliance under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Decreased from 188 to 157 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Increased from 3,106 to 3,148 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Added cost equivalent estimate for this information
collection. Increased from $0 to $853,108 after
considering internal costs of compliance under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Increased from 432 to 611 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Increased from 257 to 361 based upon data
obtained since the prior PRA renewal process in
2023.

Information Collections (ICs)

Area of Change

Cost Burden ($)

No. of Responses

Rule 15Ba1-1(m)(3): Exception to
Time Burden (Hours)
Definition of Proceeds of Municipal
Securities
Cost Burden ($)

16.

Reason for Change in Burden Estimates
Change Due to Adjustment in Agency Estimate –
Added cost equivalent estimate for this information
collection. Increased from $0 to $97,831 after
considering internal costs of compliance under the
Commission’s Updated Methodology.
Change Due to Adjustment in Agency Estimate –
Increased from 479 to 669 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Increased from 409 to 500 based upon data
obtained since the prior PRA renewal process in
2023.
Change Due to Adjustment in Agency Estimate –
Added cost equivalent estimate for this information
collection. Increased from $0 to $135,589 after
considering internal costs of compliance under the
Commission’s Updated Methodology.

Plans for Publishing Results

The results of this information collection are published on the Commission’s EDGAR system
and on SEC.gov. For example: (i) since 2014, copies of filed forms and related data have been made
available, on an ongoing basis, on the Commission’s EDGAR system; 237 (ii) since March 2015, a list of
registered municipal advisors has been published, and updated on a monthly basis, on an “Information
About Registered Municipal Advisors” webpage on SEC.gov;238 and (iii) since August 2025, statistics
related to municipal advisors registered with the Commission have been published, and updated on a
quarterly basis, on a “Statistics & Data Visualizations” webpage on SEC.gov.239

17.

Approval to Omit Display of OMB Expiration Date

We request authorization to omit the expiration date on the electronic version of each form.
Including the expiration date on the electronic version of each form will result in increased costs,
because the need to make changes to the forms may not follow the application’s scheduled version
release dates. The OMB control number will be displayed.

18.

Exceptions to the Certification for Paperwork Reduction Act Submissions
This collection complies with the requirements in 5 CFR 1320.9 .

237

EDGAR Full Text Search, https://www.sec.gov/edgar/search.

238

Information About Registered Municipal Advisors, https://www.sec.gov/data-research/sec-markets-data/informationabout-registered-municipal-advisors.

239

Statistics & Data Visualizations: Municipal Advisors, https://www.sec.gov/data -research/statistics-datavisualizations/municipal-advisors.

U.S. Securities and Exchange Commission (SEC)
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