Suitability for SMMPs
Dealers are exempt from Rule G-19's customer-specific suitability obligation when an institutional client is a sophisticated municipal market professional (SMMP). Recall that SMMPs are customers that are one of the following:
• Banks
• Savings and loan associations
• Insurance companies
• Investment companies
• Registered investment advisers
• Any other person or entity having total assets of at least $50 million
And the broker-dealer must reasonably believe it is capable of independently evaluating investment risks and market value. An SMMP must affirmatively indicate that it is exercising independent judgment in evaluating the recommendations o