Commission Daniel M. Gallagher
SEC Open Meeting, Washington, D.C.
Sept. 18, 2013
Thank you Chair White. I would like to thank the staff for all of the hard work that went into today’s adopting release. In particular, I’d like to acknowledge the tremendous efforts of John Cross, Jessica Kane, Mary Simpkins, Molly Kim, Rebecca Olsen and Jenna Dodd. I also want to acknowledge the excellent work of the various offices and divisions that worked on this important rulemaking.
Notwithstanding the importance of today’s adopting release, and the need to provide critical clarity to the markets, I would be remiss if I didn’t take the opportunity to note that the rulemaking mandate for municipal advisor registration is a perfect example of the many Dodd-Frank mandates that are not related to, or designed to address, the causes of the financial crisis. And the artificial, inappropriate Congressional deadline for this rulemaking resulted in a hurried and, frankly, substandard original proposal. I do not blame the staff for this; they did yeoman’s work under an unrealistic timeline. However, the rushed process for the proposing release resulted in a flawed document that, in turn, led to market confusion and alarm. Here we are almost three years later, having taken the time to produce what I hope to be a rational framework for municipal advisor registration and implementation of the mandated registration regulation. I am pleased to be able to support its adoption. And I look forward to working with the Municipal Securities Rulemaking Board on their related rules and to seeing their economic analysis on those rules.