Who is responsible for establishing and maintaining an MSRB compliance program within an organization?

• A. The issuer is responsible.
• B. The clients themselves are responsible.
• C. The broker-dealer or municipal advisor firm is responsible for establishing and maintaining an MSRB compliance program.
• D. The regulators are responsible.

Answer: (C)

The key idea is that the entity with the day-to-day ability to shape and enforce policies—the broker-dealer or municipal advisor firm—must establish and maintain its MSRB compliance program. Firms are required to have written supervisory procedures, designate a compliance professional, train staff, keep thorough records, and conduct ongoing reviews to ensure all activities align with MSRB rules. This internal program is how a firm prevents violations and demonstrates due care.

Issuers and clients aren’t in charge of running a firm’s compliance framework; they interact with the market under the rules, but the firm itself is responsible for its own compliance infrastructure. Regulators oversee and enforce MSRB rules, but they don’t operate a firm’s internal program.