Disclosure of Conflicts of Interest and Legal or Disciplinary Events
Pursuant to Municipal Securities Rulemaking Board (“MSRB”) Rule G-42, on Duties of Non-Solicitor Municipal Advisors, Municipal Advisors are required to make certain written disclosures to clients which include, amongst other things, Conflicts of Interest and any Legal or Disciplinary events of Swap Financial Group, LLC and its associated persons.
Conflicts of Interest
Swap Financial Group, LLC represents that in connection with the issuance of municipal securities, Swap Financial Group, LLC may receive compensation from an Issuer or Obligated Person for services rendered, which compensation is contingent upon the successful closing of a transaction and/or is based on the size of a transaction. Consistent with the requirements of MSRB Rule G-42, Swap Financial Group, LLC hereby discloses that such contingent and/or transactional compensation may present a potential conflict of interest regarding Swap Financial Group, LLC’s ability to provide unbiased advice to enter into such transaction. This conflict of interest will not impair Swap Financial Group, LLC’s ability to render unbiased and competent advice or to fulfill its fiduciary duty to the Issuer.
If Swap Financial Group, LLC becomes aware of any additional potential or actual conflict of interest after this disclosure, Swap Financial Group, LLC will disclose the detailed information in writing to the Issuer in a timely manner.
Legal or Disciplinary Events
Swap Financial Group, LLC does not have any legal events or disciplinary history on Swap Financial Group, LLC’s Form MA and Form MA-I, which includes information about any criminal actions, regulatory actions, investigations, terminations, judgments, liens, civil judicial actions, customer complaints, arbitrations and civil litigation. The Issuer may electronically access Swap Financial Group, LLC’s most recent Form MA and each most recent Form MA-I filed with the Commission at the following website: www.sec.gov/edgar/searchedgar/companysearch.html.
There have been no material changes to a legal or disciplinary event disclosure on any Form MA or Form MA-I filed with the SEC. If any material legal or regulatory action is brought against Swap Financial Group, LLC, we will provide complete disclosure to the Issuer in detail allowing the Issuer to evaluate Swap Financial Group, LLC, its management and personnel.