3.3.  Municipal Advisor Records

Every municipal advisor should make and keep true and accurate records of the following for at least five years, the first two years in an easily accessible place. The records can be stored electronically or in paper form. The records include:

• Originals or copies of all written communications received

• Originals or copies of all written communications sent by the municipal advisor (including inter-office memos)

• Check books, bank statements, general ledgers, cancelled checks, and cash reconciliations of the municipal advisor

• A copy of each version of the municipal advisor’s policies and procedures that are current or were kept within the last five years

• A copy of any document created by the municipal advisor that was material to making a recommendation to a municipal entity or obligated person

• All written agreements (or copies of) entered into by the municipal advisor with any municipal entity, employee of a municipal entity, or an obligated person or otherwise relating to the business of such municipal advisor as such

• A record of the names of persons who are currently, or within the past five years were, associated with the municipal advisor, not including persons associated with the municipal advisor prior to July 1, 2014

Municipal advisors must als