In communicating with clients, how should a dealer disclose material conflicts of interest related to a muni security transaction?

• A. Provide timely, clear disclosure of material conflicts and how they are addressed
• B. Disclose only after the trade is executed
• C. Omit conflicts if the client signs a general waiver
• D. Disclose conflicts only if asked by the client

Answer: (A)

Disclosing material conflicts of interest to clients must be timely and clear, with a straightforward explanation of how the conflict is addressed. This lets the client understand any potential bias before or at the time of the muni security transaction, so they can make an informed decision. Waiting to disclose after the trade, or only after the client asks, or relying on a generic waiver, would deprive the client of crucial context and undermine fair dealing. A dealer should identify the conflict, explain its potential impact on the transaction, and describe the steps taken to mitigate or manage it, ensuring transparency and maintaining trust.