Recordkeeping Responsibilities

When a syndicate has not been formed for a primary offering, these records must be maintained by the sole underwriter:

• • Description and aggregate par value of the securities
• • Statement of all terms and conditions required by the issuer
• • All orders received for the purchase of the securities from the underwriter
• • All allotments of securities and the price at which sold
• • Those instances in which the underwriter accorded equal or greater priority to orders for its own account or its related accounts over other orders and the reasons for doing so
• • Date and amount of any good faith deposit made to the issuer
• • Date of settlement with the issuer.

When a syndicate has been formed for the purchase of municipal securities, the syndicate manager must maintain these additional records:

• • Name and percentage of participation of each member of the syndicate
• • Terms and conditions governing the formation and operation of the syndicate
• • All orders received for the purchase of the securities from the syndicate
• • Date of the closing of the account
• • Reconciliation of profits and expenses of the account

Every syndicate manager must keep a record of all documents, notices, and information that it submits to the MSRB and to NIIDS. NIIDS information includes the Time of Formal Award, the Time of First Execution, and the time the new issue received NIIDS trade eligibility status.

Every syndicate member and selling group member must keep a record of all documents, notices, or written disclosures that it provided to purchasers of the offered securities.

Primary offering records and continuing disclosure statements must be kept and maintained for not less than six years. Records pertaining to the delivery of official statements to EMMA must be maintained for not less than four years (except for