Since this guidance does not seem to offer clear dividing lines or safe harbors, it will be interesting, as you, your lawyers and the MA’s you work with review this, to get feedback on the utility and consequences of this guidance. Can it be used to justify and move forward with some current arrangements or is the effect that MA’s will be clearly separated into the camp of working for and assisting issuers only or borrowers only?
Anyways, I would appreciate any feedback. The guidance is final but MSRB will accept comments and questions on this guidance which is subject to revision.