programs Treasury and Financial Systems

Independent Registered Municipal Advisor (IRMA) Exemption Letter

March 24, 2020

By publicly posting the following written disclosure, the Comptroller of Public Accounts intends that market participants may receive and use it for purposes of qualifying for the independent registered municipal advisor exemption to the U. S. Securities and Exchange Commission Municipal Advisor Rule (in accordance with Section 15B(e)(4)(c) of the Securities Exchange Act of 1934) until December 31, 2021 or until otherwise withdrawn or replaced by the Issuer.

The Texas Comptroller of Public Accounts (the “Comptroller” or “Issuer”) has retained Stifel, Nicolaus & Co., Inc. (“municipal advisor”) to provide advice on recommendations and other advice received from financial services firms concerning the issuance of municipal securities for state cash flow purposes. The Issuer will rely on the municipal advisor by seeking and considering its advice, analysis, and perspective before acting on any recommendation or other advice, although the Issuer may not necessarily follow the municipal advisor’s advice and may also rely on representations, if any, made by financial services firms in proposals made to the Issuer in reliance upon this letter.

Financial services firms that wish to learn the identity of individuals at the municipal advisor who will participate in advising the Issuer (so that they may determine whether the municipal advisor is independent) should contact Gary Machak at the address set forth below. A copy of written representations regarding the exemption may also be sent to the municipal advisor at the same address:

Gary Machak
Stifel, Nicolaus & Co., Inc.
8115 Preston Road, Suite 225
Dallas, Texas 75225
469-696-5348

If you have any questions about this letter, please contact:

Meagan Bunker
State Cash Flow Analyst
Texas Comptroller of Public Accounts
512-463-4914