his matter involves Respondent’s role in certain improper bidding practices that occurred, from at least 1998 through 2002 (the “relevant time period”), involving the temporary investment of proceeds of tax-exempt municipal securities in reinvestment products, such as guaranteed investment contracts (“GICs”), repurchase agreements (“Repos”), and forward purchase agreements (“FPAs”). As described below, these practices affected the prices of the reinvestment products and jeopardized the tax-exempt status of the underlying municipal securities. Res