ClaimHour

Vertical guide · Updated June 2026

Municipal securities attorney time tracking: SEC Rule 15c2-12 continuing disclosure obligation advisory, MSRB examination advisory, and SEC Form MA annual update advisory

Municipal securities attorneys advising municipal bond issuers and obligated persons on SEC Rule 15c2-12, 17 C.F.R. § 240.15c2-12, continuing disclosure obligations on the annual financial information filing deadline calendar, preparing municipal securities dealers for FINRA examinations under MSRB Rules G-27 (Supervision) and G-17 (Fair Dealing) on FINRA's examination notification schedule, and advising registered municipal advisors on SEC Form MA annual updates under Exchange Act § 15B, 15 U.S.C. § 78o-4, on the annual Form MA update deadline — whose time records must satisfy the municipal securities compliance documentation standard and the EMMA disclosure completeness requirement — generate three billing gaps driven by the issuer-specific annual disclosure deadline calendar, the unannounced FINRA examination notification timeline, and the fiscal year-end Form MA annual update cycle: SEC Rule 15c2-12 continuing disclosure obligation advisory calls on the annual disclosure deadline calendar (5 clients × 4 calls × 40 min × 55% untracked ≈ 7.4 hrs = $3,330–$5,550/year at $450–$750/hr), MSRB examination advisory calls on FINRA's examination schedule for municipal securities dealers (3 clients × 4 calls × 38 min × 55% ≈ 4.1 hrs = $1,845–$3,075/year at $450–$750/hr), and SEC Form MA annual update advisory calls on the annual update deadline (4 clients × 2 calls × 35 min × 55% ≈ 2.6 hrs = $1,170–$1,950/year at $450–$750/hr). For a municipal securities solo practice, the annual billing gap is $6,345–$10,575.

TL;DR

ClaimHour captures every SEC Rule 15c2-12 annual financial information filing advisory call that arrives on the issuer's continuing disclosure agreement deadline calendar, every FINRA municipal securities dealer examination notification advisory call that arrives on FINRA's unannounced examination scheduling calendar, and every SEC Form MA annual update advisory call that arrives within 90 days of each municipal advisor's fiscal year end — passively, no timer, no audio, no call contents. $29–$59/mo. No PMS required.

SEC Rule 15c2-12 continuing disclosure advisory: calls on the annual disclosure deadline calendar

SEC Rule 15c2-12, 17 C.F.R. § 240.15c2-12, prohibits broker-dealers acting as underwriters from purchasing or selling new municipal securities in primary offerings of $1 million or more unless the issuer or obligated person has entered into a continuing disclosure agreement (CDA) obligating the issuer to provide annual financial information and notices of material events to the MSRB's EMMA system. Rule 15c2-12's 2018 amendments (Release 34-83885) expanded the material event notice categories to include failure to provide annual financial information on or before the date specified in the CDA, incurrence of a financial obligation that may affect the security holders, and occurrence of events reflecting financial difficulties. Municipal securities attorneys advising municipal bond issuers, conduit borrowers, and other obligated persons on their Rule 15c2-12 continuing disclosure obligations generate advisory calls across four stages of the annual disclosure calendar: the annual financial information filing preparation stage (in the weeks before the CDA-specified annual filing deadline), the audited financial statements filing stage (when the governmental issuer's annual audit is completed and must be filed on EMMA), the material event notice assessment stage (when changes in the issuer's financial condition require assessment against the Rule 15c2-12(b)(5)(i)(C) material event categories), and the EMMA filing confirmation stage (after annual filings are submitted to the MSRB's EMMA system). Because each issuer's CDA specifies a different annual filing deadline based on the issuer's fiscal year end and the number of days after fiscal year end specified in the CDA, advisory calls arrive on a client-by-client annual disclosure calendar rather than a single uniform deadline — creating billing gaps spread across multiple months that do not cluster on a single date but arrive continuously throughout the year.

Four SEC Rule 15c2-12 continuing disclosure advisory call types that arrive on the annual disclosure deadline calendar: (1) annual financial information filing preparation advisory call — arrives 4–6 weeks before the CDA-specified annual financial information filing deadline, when counsel must review the prior year's annual financial information filing for completeness against the CDA's required disclosure categories, identify changes in the issuer's financial condition that may require new or updated disclosures, and advise on the sufficiency of the draft annual financial information for filing on EMMA (38–48 min) — on each issuer's individual annual disclosure deadline calendar; (2) audited financial statements filing advisory call — arrives when the issuer's governmental auditor completes the annual audit and delivers the audited financial statements, when counsel must advise on the timing of the EMMA filing relative to the CDA's audited financial statements filing deadline, the EMMA filing process for the audited statements, and any discrepancies between the draft annual financial information and the final audited statements that may require a corrective filing (38–48 min); (3) material event notice assessment advisory call — arrives when the issuer advises counsel of a potential material event (rating change, failure to pay, tender offer, bankruptcy or insolvency filing, or financial obligation incurrence that may affect security holders), when counsel must advise on whether the event triggers a material event notice obligation under Rule 15c2-12(b)(5)(i)(C), the content requirements for the notice, and the 10-business-day filing deadline under the Rule (38–48 min); (4) EMMA filing confirmation and continuing disclosure program review advisory call — arrives after the annual financial information and any required material event notices are filed on EMMA, when counsel must confirm that EMMA accepted all required filings, review the issuer's continuing disclosure record on EMMA for accuracy and completeness, and advise on the risk of SEC examination or investor litigation arising from any prior years' failures to file required disclosures on time (33–43 min). At 55% untracked: 5 clients × 4 calls × 40 min × 55% = 440 min / 60 ≈ 7.3 hours (≈ 7.4 hours) = $3,330–$5,550/year at $450–$750/hr.

MSRB examination advisory: calls on FINRA's examination schedule for municipal securities dealers

The Municipal Securities Rulemaking Board regulates broker-dealers and banks involved in municipal securities underwriting, trading, and sales through a comprehensive set of municipal securities rules — including MSRB Rule G-27 (Supervision), MSRB Rule G-17 (Fair Dealing), MSRB Rule G-20 (Gifts, Gratuities, Non-Cash Compensation), MSRB Rule G-14 (Reports of Sales or Purchases), MSRB Rule G-37 (Political Contributions and Prohibitions on Municipal Securities Business), and MSRB Rule G-42 (Duties of Non-Solicitor Municipal Advisors). For broker-dealer municipal securities dealers, these rules are enforced by FINRA through FINRA's examination program: FINRA examiners review municipal securities dealers for compliance with MSRB rules during cycle examinations of the broker-dealer, using FINRA's examination notification process to initiate the examination on FINRA's scheduling calendar. Municipal securities attorneys advising municipal securities dealers on FINRA examination preparation must address both the general FINRA Rule 3110 supervisory examination requirements and the MSRB-specific rules that FINRA examiners have historically focused on in municipal securities dealer examinations — including MSRB Rule G-37's political contribution prohibitions, which restrict municipal securities business for two years following a covered contribution to a municipal official. Advisory calls arrive across four stages of FINRA's examination notification timeline.

Four MSRB examination preparation advisory call types that arrive on FINRA's examination schedule for municipal securities dealers: (1) FINRA examination notification and MSRB rules compliance assessment advisory call — arrives when FINRA sends the examination notification letter, when counsel must review the initial document requests for MSRB-specific compliance areas, assess the municipal securities dealer's written supervisory procedures for MSRB Rule G-27 compliance, and identify any prior-year MSRB rule compliance issues that require remediation before the examination (35–45 min) — on FINRA's examination notification calendar; (2) MSRB Rule G-37 political contribution records review advisory call — arrives when FINRA's examination requests include the broker-dealer's Rule G-37 contribution reports and written supervisory procedures for political contribution compliance, when counsel must review the firm's quarterly Rule G-37 contribution reports filed with the MSRB, assess the adequacy of the firm's political contribution pre-clearance procedures, and advise on any required corrective actions for historical contribution compliance issues (35–45 min); (3) MSRB Rule G-17 fair dealing and MSRB Rule G-20 gifts examination advisory call — arrives when FINRA examines the broker-dealer for compliance with MSRB Rule G-17's fair dealing obligations in municipal securities transactions and MSRB Rule G-20's gift and gratuity limitations ($100 per year to public officials), when counsel must review the firm's gift log, advise on the Rule G-17 duty to deal fairly in complex municipal securities transactions, and assess the firm's underwriting business conflict-of-interest disclosure obligations under MSRB Rule G-17(b) (35–45 min); (4) preliminary and formal FINRA findings advisory call — arrives when FINRA shares preliminary or formal examination findings related to MSRB rule compliance, when counsel must advise on the significance of FINRA's MSRB-specific examination findings, the available rebuttal arguments against FINRA's MSRB rule interpretations, and the corrective action plan for any identified MSRB compliance deficiencies (33–43 min). At 55% untracked: 3 clients × 4 calls × 38 min × 55% = 250.8 min / 60 ≈ 4.1–4.2 hours = $1,845–$3,075/year at $450–$750/hr.

SEC Form MA annual update advisory: calls on the annual update deadline

Dodd-Frank Act § 975, codified at Exchange Act § 15B, 15 U.S.C. § 78o-4, created a comprehensive regulatory framework for municipal advisors — including registered municipal advisors that provide financial advice to municipal issuers, broker-dealer underwriters advising municipal issuers beyond their underwriting role, and independent registered municipal advisors providing investment advice to municipalities on the investment of bond proceeds. SEC-registered municipal advisors must file Form MA annually within 90 days after the end of the municipal advisor's fiscal year to update their registration information, and must file Form MA-I amendments within 30 days of any material change in a natural person municipal advisor's information. The Form MA annual update advisory call burden arises because the Form MA requires extensive disclosure of the municipal advisor's activities, conflicts of interest, and regulatory history: the Form MA's annual update must reflect changes in the types of municipal advisory activities conducted, the types of clients served, the fee arrangements, and the disciplinary history of the municipal advisor and its associated persons. Municipal securities attorneys advising registered municipal advisors on Form MA annual updates generate advisory calls across two stages of the annual Form MA update process: the Form MA update scope review advisory (assessing required updates to the municipal advisor's Form MA registration and the Form MA-I brochures for each associated person) and the Form MA annual update filing advisory (reviewing the draft Form MA annual update for accuracy and filing on SEC EDGAR within the 90-day deadline).

Two SEC Form MA annual update advisory call types that arrive on the annual update deadline: (1) Form MA annual update scope review and compliance assessment advisory call — arrives 4–6 weeks before the 90-day annual update deadline (i.e., approximately 2.5–3 months after fiscal year end for most municipal advisors), when counsel must review the prior year's Form MA for accuracy, identify changes in the municipal advisor's activities, clients, and compensation arrangements that require disclosure, assess whether any events during the year — enforcement actions, court orders, arbitration awards, or formal investigations — require disclosure under Form MA's disciplinary disclosure requirements, and identify any associated persons requiring Form MA-I amendments (33–40 min) — on the annual Form MA update deadline calendar; (2) Form MA annual update draft review and filing confirmation advisory call — arrives 1–2 weeks before the 90-day annual update deadline, when counsel reviews the draft Form MA annual update for accuracy, completeness of the conflicts-of-interest disclosure required under Exchange Act § 15B(c)(1) and SEC Rule 15Ba1-8, 17 C.F.R. § 240.15Ba1-8 (Books and Records Rule for Municipal Advisors), and confirms that the Form MA annual update was accepted by SEC EDGAR and that any required Form MA-I amendments were filed within the 30-day amendment deadline (33–40 min). At 55% untracked: 4 clients × 2 calls × 35 min × 55% = 154 min / 60 ≈ 2.6 hours = $1,170–$1,950/year at $450–$750/hr.

How ClaimHour fits municipal securities practice

If you advise municipal bond issuers on SEC Rule 15c2-12 continuing disclosure obligations with annual financial information filing preparation advisory calls and material event notice assessment advisory calls arriving throughout the year on each issuer's individual CDA-specified annual disclosure deadline, prepare municipal securities dealers for FINRA examinations with examination notification advisory calls and MSRB Rule G-37 political contribution records review advisory calls arriving on FINRA's unannounced examination scheduling calendar, and advise registered municipal advisors on Form MA annual updates with update scope review advisory calls and Form MA filing confirmation advisory calls arriving within 90 days of each advisor's fiscal year end — and your invoices consistently understate the EMMA filing confirmation advisory calls that arrive after the annual disclosure deadline, the MSRB Rule G-17 fair dealing examination advisory calls that arrive during FINRA's on-site examination, and the Form MA-I amendment advisory calls that arrive on the 30-day amendment filing deadline — ClaimHour was built for that gap.

Get early access

Related questions

How do SEC Rule 15c2-12 continuing disclosure advisory calls generate billing gaps on the annual disclosure deadline calendar?

Each issuer's continuing disclosure agreement specifies a different annual filing deadline based on fiscal year end, creating issuer-by-issuer deadline-driven advisory calls throughout the year. Four call types: annual financial information filing preparation advisory (38–48 min), audited financial statements filing advisory (38–48 min), material event notice assessment advisory (38–48 min), and EMMA filing confirmation advisory (33–43 min). At 55% untracked: 5 clients × 4 calls × 40 min × 55% ≈ 7.4 hours = $3,330–$5,550/year at $450–$750/hr.

How do MSRB examination advisory calls generate billing gaps on FINRA's examination schedule?

FINRA examines municipal securities dealers for compliance with both FINRA Rule 3110 supervisory requirements and MSRB-specific rules (G-27 Supervision, G-17 Fair Dealing, G-37 Political Contributions) on FINRA's unannounced examination notification calendar. Four call types spanning examination notification advisory (35–45 min) through formal findings advisory (33–43 min). At 55% untracked: 3 clients × 4 calls × 38 min × 55% ≈ 4.1 hours = $1,845–$3,075/year at $450–$750/hr.

How do SEC Form MA annual update advisory calls generate billing gaps on the annual update deadline?

Registered municipal advisors must file Form MA annual updates within 90 days of fiscal year end, and advisory calls cluster in the 4–6 week window before each advisor's individual deadline. Two call types: Form MA annual update scope review advisory (33–40 min) and Form MA draft review and filing confirmation advisory (33–40 min). At 55% untracked: 4 clients × 2 calls × 35 min × 55% ≈ 2.6 hours = $1,170–$1,950/year at $450–$750/hr.

How does municipal securities attorney billing differ from securities regulation attorney billing?

Securities regulation attorney billing centers on SEC and FINRA regulation of registered investment advisers and broker-dealers (Form ADV, SEC EXAM, FINRA examination). Municipal securities attorney billing centers on MSRB-regulated municipal obligations: Rule 15c2-12 continuing disclosure advisory on issuer-specific annual deadlines, MSRB examination advisory on FINRA's examination notification calendar, and Form MA annual update advisory on each municipal advisor's fiscal year-end deadline. Combined annual billing gap: 7.4 + 4.1 + 2.6 = 14.1 hours = $6,345–$10,575/year.

Further reading