MSRB Rule G-43

General Obligations

The firm’s obligations when acting as a broker include;

Realization of offers

In carrying out a solicited promotion, VIP Advisors LLC will use reasonable efforts to widely advertise a property (including, but not limited to, partners, portfolio of listed companies, and future bidders for the issuance) to gain exposure to multiple clients with potential interest in the property indicated sector. A fixed number of offers is not required.

For securities of broad interest, VIP Advisors LLC intends to use telephone promotion, via e-mail, presentations in order to disseminate its sales offers.

For limited interest securities, VIP Advisors LLC will make a reasonable effort to reach dealers known to VIP Advisors LLC to have specific knowledge of the issue or known to VIP Advisors LLC to have a known interest in securities of the type being offered.

VIP Advisors LLC will not limit the audience for a requested offer (for example, through the use of filters) unless the seller explicitly indicates to do so.

In the event that VIP Advisors LLC is ordered to limit the dissemination of a requested offer by the seller, it will document (in writing) such instructions and the reasons for limiting the dissemination of the requested offer.

VIP Advisors LLC will adopt default parameters of system, prior to the auction in which they are used. VIP Advisors LLC will periodically test the default parameters to determine if they have identified a majority of the offers that did not represent the fair market value of the municipal securities that were the subject of offers to which the default parameters were applied.

Each solicited bid must have a bid acceptance deadline, after which the company will not accept any bids or accept any changes to bids. Such term will be an “acute” term or an “around time” term. For approximate terms, VIP Advisors LLC will not accept offers or changes in offers after whichever occurs first: the time the seller instructs VIP Advisors LLC to sell the securities to the current highest bidder; or the end of the day of acceptance according to the results obtained by VIP Advisors LLC.


Membership Features Disclosures:

Through the website, by telephone and/or in person, VIP Advisors will prominently disclose to its clients:

Characteristics of the properties in promotion, VIP advisors’ broker procedures; Base price, time of presentation and availability of property.


As a broker, VIP Advisors is prohibited from: -maintaining retained properties or other assets, other than for clearance and settlement purposes;

  • self-dealing;
  • encouraging bids that do not represent the fair market value of municipal securities that are the subject of a bid-wanted or offering;
  • giving preferential information to bidders in bid-wanted, including but not limited to, “last looks” directions to a specific bidder that should “review” its bid or that its bid is “sticking out”;
  • changing a bid price or offer price without the bidder’s or seller’s respective permission;
  • subject to the provisions of bid-wanted requirements, if applicable, and the prohibition in the above bullet, providing any person other than the seller (which may receive all bid prices) and the winning bidder (which may only receive notice that its bid is the winning bid) with information about bid prices, until the bid-wanted has been completed, unless the Firm makes such information available to all market participants on an equal basis at no cost, together with the disclosure that nay bids may not represent the fair market value of the securities, and discloses publicly that it will make such information public.