MSRB NOTICE 2004-20 (JUNE 24, 2004)

REAL-TIME TRANSACTION REPORTING: SUMMARY OF CERTIFICATION TEST PLAN

BACKGROUND

All brokers, dealers and municipal securities dealers (collectively, “dealers”) will be required to report municipal securities trades in real-time by January 2005, the planned effective date of revised Rule G-14, and to submit inter-dealer trades for real-time comparison beginning on the same date, as required by revised Rule G-12(f).[1]   Before real-time reporting and comparison rules become effective, every dealer that effects transactions subject to Rule G-14 must be certified to report trades to the MSRB.[2] 

The MSRB has published a Certification Test Plan, which is available on its web site.  (To access the Plan, click here.)  The plan provides that each clearing broker that has a direct telecommunications connection to NSCC’s Real-Time Trade Matching (RTTM) system, which is the vehicle for reporting data to RTRS, must conduct the full certification test.[3]  If all of a dealer’s transaction reports are submitted and updated by an agent (a clearing broker or service bureau), then the dealer will be certified when its agent is certified.

SUMMARY OF TEST

In summary, the major steps in certification testing are:

Complete Form RTRS.  Form RTRS informs the MSRB of the dealer’s trade reporting method.  Every dealer registered with the MSRB must complete this form.  Form RTRS is described separately.[4] 

Determine the dealer’s role and the role of its agent (if any) in testing.  A determination is made as to what parts of the certification test the dealer must conduct itself and what parts its agent may conduct on its behalf.  Many relationships are possible in addition to the “clearing broker” and “certified by agent” relationship outlined above.  MSRB staff, in a telephone conversation with the dealer staff, will assist in this determination.

Customize and plan a dealer’s test.   The dealer and the MSRB will jointly determine which test messages and scenarios are appropriate to the dealer’s municipal securities business. 

Schedule test.  The dealer will have provided a preferred date for testing on Form RTRS.  The dealer and the MSRB will jointly schedule an actual date.

Construct test trades.  From the list of general list test trades, the dealer will construct test messages or prepare to enter trades using the RTRS Web interface. 

Set up telecommunications connection.  The dealer will set up the necessary connection, if this is not already in place. 

Obtain RTTM certification.  NSCC participants must obtain RTTM certification before proceeding with RTRS certification.  Correspondents must verify that their clearing broker has obtained RTTM certification before proceeding with RTRS testing.

Submit test trades to RTRS.  If the dealer is conducting the test itself, it will submit the test trades. 

Receive RTRS feedback.  RTRS will provide feedback indicating whether the test trades have errors or are satisfactory.  If the submissions are other than “Satisfactory,” the dealer makes the necessary modifications by providing further input.

Certification.  The dealer will send the control numbers of “Satisfactory” trades to the MSRB by e-mail.  The MSRB will verify the trades and notify the dealer that it is certified or that there are deficiencies in the input.

MILESTONES

Certification testing with dealers begins July 1, 2004.  Dealers must be certified by January 2005, the expected date of effectiveness of the real-time reporting requirement.  The Certification Test Plan provides further details.

RTRS SYSTEM DOCUMENTATION

To access RTRS documentation, click here.  This link to the MSRB web site leads to a description of the proposed change to Rules G-14 and G-12(f), RTRS system specifications, questions and answers on real-time reporting, and all related MSRB notices.

June 24, 2004


[1] See Notice 2004-13, “Real-Time Transaction Reporting:  Notice of Filing of Proposed Rule Change to Rules G-14 and G-12(f)” (June 1, 2004) on www.msrb.org.

[2] Dealers that effect trades in municipal fund securities, but no other municipal securities, are exempted from testing because Rule G-14 does not require such trades to be reported.

[3] A clearing broker has a direct connection to RTTM if it submits messages to RTTM without the aid of a service bureau.  The dealer may obtain support from a vendor, but if the vendor does not support other dealers the vendor is not considered as a service bureau and the dealer has a “direct” connection.

[4] See Notice 2004-21, “MSRB Makes Form RTRS Available On-Line” (June 24, 2004) on www.msrb.org.