IF-2 Short-Term Obligation Rate Transparency System

Short-Term Obligation Rate Transparency System

Short-Term Obligation Rate Transparency System

The Short-term Obligation Rate Transparency (“SHORT”) System is a facility of the Municipal Securities Rulemaking Board (“MSRB”) for the collection and dissemination of information and documents about securities bearing interest at short-term rates and making such information and documents publicly available through a dissemination service. 

Submissions to the SHORT System

The SHORT System receives submissions of information and documents about securities bearing interest at short-term rates under MSRB Rule G-34, on CUSIP numbers, new issue and market information requirements.

Information and Documents to be Submitted.  The basic items of information and documents required to be submitted to the SHORT System are the same as those required to be submitted to the MSRB under MSRB Rule G-34(c).  Submitters of documents shall provide to the SHORT System related indexing information with respect to each document submitted, including an indication of the document type, date such document became available to the broker, dealer or municipal securities dealer, and CUSIP number(s) of the municipal securities to which such document relates.  A submitter required to submit a document that is already available in its entirety in the SHORT System may, in lieu of submitting a duplicate document, identify the document already submitted and provide such items of related indexing information as are required by MSRB rules or the SHORT System input specifications and system procedures.  A submitter required to submit a document that is not able to be obtained through best efforts as provided in Rule G-34(c) must provide an affirmative indication that a document required to be submitted is not available for submission notwithstanding the submitter’s best efforts to obtain such document.  The complete list of data elements that are required on a submission to the SHORT System is available in input specifications and system procedures made available on www.msrb.org.  Submitters shall be responsible for the accuracy and completeness of all information submitted to the SHORT System.

Submitters.  Submissions to the SHORT System may be made solely by authorized submitters using password-protected accounts in the MSRB’s user authentication system, MSRB Gateway.  MSRB Gateway is designed to be a single, secure access point for all MSRB applications.  Submitters of information to the SHORT System are required to obtain an account in MSRB Gateway in order to submit information to the SHORT System.  Through MSRB Gateway, submitters also have the ability to designate third-party agents to submit information to the SHORT System on the submitter’s behalf.  

 Submissions may be made by the following classes of submitters:

  • Auction Rate Security (“ARS”) Program Dealer;
  • Variable Rate Demand Obligation (“VRDO”) Remarketing Agent;
  • ARS Auction Agent; and
  • Designated Agent, which may submit any information otherwise permitted to be submitted by another class of submitter which has designated such agent, as provided below.

All ARS Auction Agents are allowed to submit information about an auction to the SHORT System without prior designation by an ARS Program Dealer.  Dealers optionally may designate agents to submit information on their behalf, and may revoke the designation of any such agents, through MSRB Gateway.  All actions taken by a Designated Agent on behalf of a dealer that has designated such agent shall be the responsibility of the dealer. 

Timing of Submissions.  Submitters are required to make submissions to the SHORT System within the timeframes set forth in MSRB Rule G-34(c) and related MSRB procedures.  Submissions of information to the SHORT System may be made throughout any RTRS Business Day, as defined in Rule G-14 RTRS Procedures, from at least the hours of 6:00 a.m. to 9:00 p.m. Eastern Time, subject to the right of the MSRB to make such processes unavailable at times as needed to ensure the integrity of the SHORT System and any related systems. Submissions of documents may be made twenty-four hours a day, seven days a week, subject to the right of the MSRB to make such processes unavailable outside of core operational hours (as described below) for required maintenance, upgrades or other purposes, or at other times as needed to ensure the integrity of MSRB systems.  The MSRB shall provide advance notice of any planned periods of unavailability and shall endeavor to provide information to submitters as to the status of the submission interface during unanticipated periods of unavailability, to the extent technically feasible. The MSRB maintains 7:00 a.m. to 7:00 p.m. Eastern Time as core operational hours on business days, which exclude weekends and holidays identified on the MSRB System Holiday Schedule published on the MSRB website. Core operational hours represent those hours when the MSRB’s resources will be more readily available to respond to inquiries and incidents experienced by users of MSRB’s systems.

Method of Submission.  Information and documents may be submitted to the SHORT System through a secure, password-protected, web-based electronic submitter interface or through a secure, authenticated computer-to-computer data connection, at the election of the submitter.  When making submissions using the web-based interface, related information is entered manually into an on-line form and documents are uploaded as portable document format (PDF) files.  Computer-to-computer submissions utilize XML files for data and PDF files for documents.  Appropriate schemas and procedures for web-based and computer-to-computer submissions are available in input specifications and system procedures made available on www.msrb.org.

Designated Electronic Format for Documents.   All documents submitted to the SHORT System must be in portable document format (PDF), configured to permit documents to be saved, viewed, printed and retransmitted by electronic means.  If the submitted file is a reproduction of the original document, the submitted file must maintain the graphical and textual integrity of the original document.  Documents submitted to the SHORT System created on or after May 16, 2011 shall be word-searchable (without regard to diagrams, images and other non-textual elements). 

SHORT System Processing

The SHORT System provides a single portal for the submission of information and documents.  The SHORT System, as well as other MSRB systems and services, performs various data checks to ensure that information and documents are submitted in the correct format.  In addition, data checks are performed to monitor dealer compliance with MSRB Rule G-34(c) as well as to identify information submitted in correct formats that may contain errors due to information not falling within reasonable ranges of expected values for a given item of information.  All submissions generate an acknowledgement or error message, and all dealers that have information or documents submitted on their behalf by either an ARS Auction Agent or a Designated Agent are able to monitor such submissions. 

SHORT System Information and Document Dissemination

Information and documents submitted to the SHORT System that pass the format and data checks described above are processed and disseminated on a real-time basis.  Any changes to submissions also are processed upon receipt and updated information and documents are disseminated in real-time.  Information submitted to the SHORT System is, in general, disseminated to the EMMA short-term obligation rate transparency service within 15 minutes of acceptance, although during peak traffic periods dissemination may occur within one hour of acceptance.  Submissions of documents to the SHORT System accepted during core operational hours (as described below) are, in general, disseminated to the EMMA short-term obligation transparency service within 15 minutes of acceptance, although during peak traffic periods dissemination may occur within one hour of acceptance.  Submissions outside of core operational hours often are disseminated within 15 minutes although some submissions outside of core operational hours may not be processed until the next business day.  SHORT System information and documents, along with related indexing information, shall be made available to the public through the EMMA portal for the life of the related securities.

The MSRB maintains 7:00 a.m. to 7:00 p.m. Eastern Time as core operational hours on business days, which exclude weekends and holidays identified on the MSRB System Holiday Schedule published on the MSRB website. Core operational hours represent those hours when the MSRB’s resources will be more readily available to respond to inquiries and incidents experienced by users of MSRB’s systems.

SHORT-TERM OBLIGATION RATE TRANSPARENCY SUBSCRIPTION SERVICE

The Short-term Obligation Rate Transparency (“SHORT”) System is a facility of the Municipal Securities Rulemaking Board (“MSRB”) for the collection and dissemination of information and documents about securities bearing interest at short-term rates, which include Auction Rate Securities (“ARS”) and Variable Rate Demand Obligations (“VRDOs”).  The SHORT subscription service, which is available for an annual fee of $11,000, makes available to subscribers data streams of all information and documents collected by the SHORT System.[1]  The MSRB may, in its discretion, waive or reduce such fees for a service or product for non-profit organizations (including institutions of higher education) and for organizations providing, at no out-of-pocket charge, services or products to the MSRB for internal or public use or dissemination on EMMA on terms agreeable to the MSRB.  Information and documents submitted to the SHORT System also are posted to the MSRB’s Electronic Municipal Market Access (EMMA) web portal pursuant to the EMMA short-term obligation rate transparency service.  Such information and documents will be made available to subscribers simultaneously with the availability of such information and documents to the EMMA web portal.  Submitters of information and documents to the SHORT System may provide or modify such items for a particular submission in one or more sessions and any such items provided or modified will be made available to subscribers simultaneously with the availability of such items to the EMMA web portal.

Data elements with respect to the SHORT subscription service to be provided through the data stream shall be set forth in the SHORT System Subscriber Manual posted on the MSRB website.  Each submission of information to the SHORT System will result in an XML data packet to be included in the subscription feed containing, to the extent applicable for each submission, some of the following data elements:

Data Element

Definition

Sequence Number

An incremental system generated number assigned to each reported transaction.

Transaction Type

Dealer-supplied transaction type to indicate that a submission is a new report, modification or cancellation.

Publication Date and Time

Date and time a submission was published.

Dealer Names

The identity of the ARS Program Dealer(s) or VRDO Remarketing Agent.

Control Number

Unique identifier used to tie transactions together in the case of a modification or cancellation.

CUSIP9

CUSIP Number for the security.

Instrument Type

Indication of whether the security is an ARS or a VRDO.

Interest Rate Reset Date and Time

ARS - Date and time that the ARS auction occurred.

VRDOs - Date and time that the VRDO interest rate was determined.

Interest Rate Period

Number of calendar days that the interest rate is applicable.

Interest Rate Posting Date and Time

ARS (only) – Date and time that the ARS auction results were communicated to ARS Program Dealers. 

Effective Date of Interest Rate

VRDOs (only) - Effective date that the interest rate reset is applicable.

Interest Rate

Interest rate, in percent.

Minimum Denomination

Minimum allowable transaction size, in par amount.

Rate Type

ARS - Indication of whether the interest rate submitted represents a maximum rate (M), all hold rate (H), or an interest rate set by the auction process (A).

VRDOs - Indication of whether the interest rate submitted represents a maximum rate, a rate that was set by a formula, or a rate that was set by the VRDO Remarketing Agent.

Minimum Rate

ARS - Minimum interest rate, in percent, applicable at the time of the auction or if such minimum interest rate is not able to be calculated, an indication that such rate is not calculable.

VRDOs - Minimum interest rate, in percent, applicable at the time of the interest rate reset or if such minimum interest rate is not able to be calculated, an indication that such rate is not calculable.

Maximum Rate

ARS - Maximum interest rate, in percent, applicable at the time of the auction or if such maximum interest rate is not able to be calculated, an indication that such rate is not calculable.

VRDOs - Maximum interest rate, in percent, applicable at the time of the interest rate reset or if such maximum interest rate is not able to be calculated, an indication that such rate is not calculable.

Notification Period

VRDOs (only) - Number of calendar days that may lapse between a holder of a VRDO tendering a position in the security and a liquidity provider purchasing the tendered security in the event that the Remarketing Agent is unable to remarket the tendered security.

Liquidity Facility Type

VRDOs (only) - For each liquidity facility applicable to a VRDO, an indication of whether it is a standby bond purchase agreement, letter of credit, or a “self liquidity” program whereby liquidity is provided by the issuer, conduit borrower or affiliate.

Liquidity Facility Expiration Date

VRDOs (only) - The expiration date of each liquidity facility applicable to a VRDO.

Identity of Liquidity Provider

VRDOs (only) - For each liquidity facility applicable to the VRDO, the identity of the liquidity provider.  This value reflects information available to the VRDO Remarketing Agent as of the date and time of the interest rate reset.

Aggregate Par Amount – Bank Bond

VRDOs (only) - Par amount of the VRDO, if any, held by liquidity providers (as a “Bank Bond”).  This value reflects information available to the VRDO Remarketing Agent as of the date and time of the interest rate reset. 

Aggregate Par Amount – Investors and Remarketing Agent

VRDOs (only) - Par amount of the VRDO, if any, held by parties other than a liquidity provider, which represents the aggregate par amounts held by the VRDO Remarketing Agent and by investors.  This value reflects information available to the VRDO Remarketing Agent as of the date and time of the interest rate reset.

Identity of Tender Agent

VRDOs (only) - For each tender agent applicable to the VRDO, the identity of the tender agent.  This value reflects information available to the VRDO Remarketing Agent as of the date and time of the interest rate reset.

Order Type

ARS (only) - Indication of whether an order is an order to buy, sell or hold at rate.

Order Interest Rate

ARS (only) - For orders to buy or hold at rate, the interest rate associated with such orders. 

Order Entity

ARS (only) - Indication of whether an order placed or that was filled is for an investor, program dealer for its own account or issuer/conduit borrower of the ARS.

Order Par Amount

ARS (only) - The aggregate par amount submitted to the auction for each order type, interest rate for buy and hold at rate orders, and order entity. 

Filled Par Amount

ARS (only) - The aggregate par amount filled as a result of the auction for each order type, interest rate for buy and hold at rate orders and order entity. 

Bid to Cover Ratio

ARS (only) - Ratio of the aggregate par amount of securities bid for the aggregate par amount of securities offered in an auction.

Each document submission to the SHORT System will result in an XML data packet to be included in the subscription feed.  Each submission event packet will include data organized in a hierarchical data relationship generally consisting of (to the extent applicable for a particular submission event) XML containers for submission data, security data and document data.  These containers will contain some, all or none of the following types of data elements, as appropriate for each submission event being disseminated:

Submission Data:       submission ID; transaction ID; submission transaction date/time

Security Data:            CUSIP number, ARS/VRDO instrument type identifier

Document Data:         document ID; document type; document posting date; document status indicator

The SHORT System Subscriber Manual provides a complete, up-to-date listing of all data elements made available through the SHORT subscription service, including any additions, deletions or modifications to disseminated data elements, detailed definitions of each data element, specific data format information, and information about technical data elements to support transmission and data-integrity processes between the SHORT System and subscribers.

Subscriptions will be provided through computer-to-computer data streams utilizing XML files for data and files in a designated electronic format (consisting of PDF files) for documents.  Appropriate schemas and other technical specifications for accessing the web services through which the data stream will be provided are set forth in the SHORT System Subscriber Manual posted on the MSRB website.

The MSRB makes the SHORT subscription service available on an equal and non-discriminatory basis.  Subscribers shall be subject to all of the terms of the subscription agreement to be entered into between the MSRB and each subscriber, including proprietary rights of third parties in information provided by such third parties that is made available through the subscription.  The MSRB is not responsible for the content of the information or documents submitted by submitters that is distributed to subscribers of the SHORT subscription service.

EMMA Short-Term Obligation Rate Transparency Historical Data Product

In addition to offering the SHORT subscription service, the MSRB offers a SHORT historical data product, which consists of the same data set (including both information and documents) as provided by the SHORT subscription service up to the end of the most recent complete month.  The SHORT historical data product may be purchased in any twelve consecutive complete month data sets for $5,000 per data set.[2]  No smaller data sets will be made available on an individual basis.[3]  The SHORT historical data product will be made available to purchasers in electronic format using a physical medium  (such as an optical disc, flash memory card or external hard drive),[4] pursuant to the terms of the MSRB Historical Transaction Data Purchase Agreement, which must be executed by purchasers prior to delivery of the data product.[5]  A one-time set-up fee of $2,000 will be charged to new purchasers of the SHORT historical data product, unless the purchaser subscribes to an MSRB Subscription Service, or previously has purchased a historical product.


[1] Subscribers to the SHORT system will be able to access historical data for the most recent six months on a daily rolling basis.  Older data is available for purchase in twelve consecutive complete month data sets pursuant to the SHORT historical data product.

[2] The purchase price does not include sales tax as required by Virginia state law.  The purchase price is a one-time charge for the SHORT historical data product and will not include any future additions or enhancements that may be added to the data. The MSRB may, in its discretion, waive or reduce fees for a service or a product for non-profit organizations (including institutions of higher education) and for organizations providing, at no out-of-pocket charge, services or products to the MSRB for internal or public use or dissemination on EMMA on terms agreeable to the MSRB.

[3] The SHORT system became effective January 30, 2009.  Accordingly, a purchaser of all historical information and documents will be charged $5,000 for each twelve consecutive month data set and a prorated amount for any remaining months of information and documents.

[4] The MSRB will choose an appropriate physical medium for delivering the SHORT historical data product based upon the quantity of data included in a data set and technological advances in physical media.

[5] Purchasers are subject to all of the terms of the purchase agreement to be entered into between the MSRB and each purchaser, including terms relating to the proprietary and intellectual property rights of third parties in information provided by such third parties that is made available through the product.