Indirect Enforcement Through Underwriters
Because of concern that the above would infringe on states’ rights, the Tower Amendment was included in the Securities Acts Amendments to ensure that the MSRB and the SEC would not have would not have direct authority over issuers of municipal securities.
In order to get around this rule and impose some indirect regulation on issuers, Rule 15c2-12 was adopted by the SEC in 1989. This rule prevents municipal securities dealers from selling municipal securities unless the issuers have ag