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.