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By retaining an independent registered municipal advisor, hospitals can qualify under an exception to the SEC MA rule and maintain communications with bankers.

Rule Background

Many not-for-profit hospitals depend on ideas from investment bankers to manage and fine-tune their debt structure.  Under the SEC Municipal Advisor Rule adopted in 2014, investment bankers wanting to discuss specific products with hospitals must first qualify under an exception to the Rule. The most flexible exception is when the hospital has retained an Independent Registered Municipal Advisor or "IRMA".


There are four exceptions to the MA Rule which may allow a broker-dealer to communicate with a municipal issuer or obligated person:

  • The hospital has retained an IRMA
  • The hospital has engaged the firm as underwriter on a specific transaction
  • The firm is responding to an RFP
  • The firm is providing general information which is not specific to the hospital.

IRMA Exception

To qualify under the IRMA exception, the hospital must retain an IRMA to specifically cover the products and services to be discussed, and the IRMA's involvement must be properly disclosed to bankers.

HFA Partners

HFA Partners, LLC is an IRMA registered with the SEC and MSRB.  Hiring HFA Partners will qualify for the IRMA exception to the Rule and will ensure that the hospital continues to receive ideas from bankers. 

More Info

What the New SEC Municipal Advisor Rule Means for Hospitals

For more information on the MA Rule and IRMA services, email or call (813) 347-9150.

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