Municipal Entity Disclosure

Before Multi-Bank Securities, Inc. (MBS) engages in a relationship with municipalities, we need to gather some information, collect some documents and explain some possible restrictions.

If MBS doesn’t know if you have bond proceeds, or if you have informed us that there will be bond proceeds, we must disclose the following:

(a) this person is not recommending an action to the municipal entity or obligated person; (b) this person is not acting as an advisor to the municipal entity or obligated person and does not owe a fiduciary duty pursuant to Section 15B of the Exchange Act to the municipal entity or obligated person with respect to the information and material contained in this communication; (c) this person is acting for its own interests; and (d) the municipal entity or obligated person should discuss any information and material contained in this communication with any and all internal or external advisors and experts that the municipal entity or obligated person deems appropriate before acting on this information or material.

Do you have bond proceeds from the issuance of debt that you intend to invest with MBS?

Yes, my municipality has bond proceeds to invest:
If you do, we need to know whether you have an Independent Registered Municipal Advisor (IRMA), as well as who your IRMA is and how to contact them.

If you DO NOT have an IRMA, we can work with you, but to be your broker dealer we have to limit our communications to “general information” and not provide you with any advice. We will send you a general information disclosure letter, and our communications with you will be responsive to your pricing inquiries and any administrative questions you may have. MBS will not suggest any investment strategy for the municipal entity, and will limit the information provided to the entity to general, publicly available information. There will be no solicitation to make an investment decision or a change in investment strategy.

No, my municipality does not have bond proceeds to invest:
If you do not have bond proceeds to invest, we will ask you to make written representations that there are no bond proceeds to be invested. Once that written representation is in place, our communications will not be subject to the restrictions on advice under the Municipal Advisor Rule.

We will ask you to make written representations on bond proceeds from time to time. We may conduct a review due to a change in investment behavior, such as sudden increases in investment amounts; evidence of any new issuance; or through a regular cadence fitting your facts and circumstances.

For additional disclosures, please click here.