On January 10th, the SEC released a 19 page FAQ (available here) on the new municipal advisor rule.
We focus your attention to the last sentence of the answer to Question 4.1
Therefore, the Staff would not object if those SEC registered investment advisers that provide advice on municipal derivatives in an investment portfolio for clients that are municipal entities or obligated persons do not register with the Commission as municipal advisors.
Good day. GOOD, NO GREAT, interpretation. TSR