However, many smaller, less frequent issuers don't use a municipal advisor when accessing the new issue market. Small, infrequent issuers may decide – perhaps after being told so – that a municipal advisor is an unnecessary expense. Unlike some larger issuers, small, infrequent issuers lack the staff expertise that can help them do well in a bond sale, Sudsina said. Underwriters aren't allowed to discourage issuers from using a municipal advisor, he noted, referencing information contained in a Municipal Securities Rulemaking Board interpretive notice . The matter involved "unfair conduct" by FMI "in connection with underwriting municipal bonds for municipal issuers," a December 2020 SEC order said.