On May 19, the SEC updated its Frequently Asked Questions Regarding the Municipal Advisor Registration Rules to clarify when the proceeds of pension obligations bonds should be treated as “proceeds of municipal securities.”  In the staff’s view, proceeds of pension obligation bonds lose their character as proceeds of municipal securities under the Final Rules upon their contribution to the public pension plan when they are commingled with other pension funds for collective investment and are treated as “spent” to carry our their authorized purposes to fund the public pension plan under applicable state law.  FAQs.