Gary Varnavides Submits MSRB Rule D-15 Comment Letter Opposing Exemption from SMMP Customer Affirmation Requirement for SEC-Registered Advisers
Gary Varnavides’s MSRB Rule D-15 comment letter argues that SEC adviser registration should not automatically reduce municipal-securities protections for investors. The core issue is whether dealers should still obtain a meaningful customer affirmation before treating an adviser as a Sophisticated Municipal Market Professional when retail investors ultimately bear the portfolio