MSRB NOTICE 2004-21a (JUNE 24, 2004)

REAL-TIME TRANSACTION REPORTING: RTRS CERTIFICATION TESTING PLAN

SUMMARY:  HOW TO TEST

All dealers registered with the MSRB that effect transactions subject to Rule G-14 must be certified to report trades via RTRS, MSRB’s Real-Time Transaction Reporting System.  Certification covers both clearing brokers and introducing (correspondent) dealers.  Each clearing broker that has a direct telecommunications connection to FICC’s Real-Time Trade Matching (RTTM) system, which is the vehicle for reporting data to RTRS, must conduct the full certification test.  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.  All dealers must complete Form RTRS, which informs the MSRB of the dealer’s trade reporting method.

To be certified, you will:

Complete Form RTRS.  We (MSRB) will send to your firm’s G-40 Primary Electronic Mail Contact a link to Form RTRS on the Board’s Web site.[1]  The Electronic Mail Contact, a registered municipal principal, or an executive of your firm will complete the form and submit it electronically to the MSRB.

Determine your role and your agent’s role in testing.  If a clearing broker or service bureau is your agent for reporting a “class” of trades (i.e., inter-dealer or customer trades), contact your agent.  If the agent will submit all data on your behalf, you will become certified for that class of trades when your agent becomes certified.  When contacting your agent, determine whether the agent will submit all transaction reports for a class of trades, including initial reports, modifications and cancellations.  Determine what test input the agent needs from your firm in order for it to conduct RTRS tests. 

If the agent submits some data for a class of trades but your firm will submit some data as well – for example, the agent initially reports trades and your firm submits corrections not to the agent but to RTRS directly – then you must conduct testing yourself.  Contact MSRB’s Transaction Reporting Assistants to customize the tests for those trades or updates that you report yourself.

Customize and plan.   Unless all trade data will be submitted by your agent, contact MSRB’s Transaction Reporting Assistants by phone to determine which test messages and scenarios are appropriate to your municipal securities business.  We will send you a customized test trade list by e-mail.  For a generic list of all test trades and scenarios, see RTRS Testing Documents.xls on www.msrb.org.

Schedule test.  You will have provided a preferred date for testing on Form RTRS.  During the customization phone conversation, your actual date will be scheduled.

Construct test trades.  From the list of test trades construct test messages or prepare to enter trades into RTRS Web.  The test trade list is general – for example, “Bilateral regular way trade as principal.”  You will determine the CUSIP number, par, price, yield, etc., for the test input.

Obtain manual format checking from MSRB.  At your option, you may e-mail test messages, as text, to the MSRB.  We will check the format and inform you of the results.  This may be particularly useful if you have not yet obtained RTTM certification.

Set up telecommunications connection.  NSCC participants will set up an MQ telecommunications connection to the RTTM test system (or set up a connection to their service bureau). Correspondents connect to their clearing broker or service bureau.  Dealers that intend to use the RTRS Web will obtain a user ID and password during the telephone conversation with the MSRB described below.  The RTRS Web Users Guide, available at www.msrb.org, will start you on the process of obtaining the necessary security certificate for your workstation.

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.  Submit the test trades and scenarios by message or the Web interface.  (See “Interfaces to be Tested,” below, regarding these methods.)  You may submit inter-dealer, customer and IDRO trades in any order.  The detailed procedures describe this step more fully.

Receive RTRS feedback.  If the submissions are other than “Satisfactory,” make the necessary modifications by providing further input.

When you receive “satisfactory” feedback on a class of trades (inter-dealer, customer or IDRO trades), put the control numbers on the customized trades list and send it by e-mail to RTRSCertTesting@msrb.org.  We will verify the trades and notify you that you are certified for this class of trades or that there are deficiencies. 

DETAILED TEST PROCEDURE

This document describes the MSRB’s Real-time Transaction Reporting System Dealer Certification Test (“RTRS Test”).  It is written for municipal securities dealers as well as service bureaus and other vendors that assist dealers in reporting transactions.  For this document, a “service bureau” is a vendor that supports more than one dealer in transaction reporting. 

Background

All dealers[2] 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).[3]   Before real-time reporting and comparison rules become effective, dealers must be certified by the MSRB by successfully testing their trade reporting systems.  Certified dealers will have the option to begin operational reporting using new formats before the required date.

Goal

The MSRB’s overall goal in conducting the RTRS Test is to ensure that the municipal securities industry will be able to report transactions in real-time.  Prior to the date for system operations, all dealers must be able to submit data to and obtain feedback from RTRS.  Dealers will submit trades, receive feedback, and make necessary corrections or cancellations, using electronic messages, Web-based screens, or both.

Who Must Test

Every dealer that effects transactions subject to Rule G-14 must be certified to report trades to the MSRB.[4]  Some dealers (typically, high-volume dealers) must be certified by testing the message-based input method themselves.  Some dealers whose agents are certified will not have to conduct tests themselves to become certified for inter-dealer trade reporting.  MSRB encourages dealers to test, especially using the RTRS Web method, even if they are not required to conduct tests.

Testing requirements apply to different types of dealers as follows:

  • A clearing broker that has a direct telecommunications connection to FICC’s Real-Time Trade Matching (RTTM) system must conduct the full certification test described in this document.[5]  This applies to self-clearing dealers and those that clear and report for others.  Clearing brokers that clear and report for others, and that have more than one interface to accept input, should take care to conduct the test for each interface.  Therefore, such a dealer must run through the test more than once.
  • A self-clearing dealer whose trades are submitted for reporting by a service bureau will be considered to be certified when the service bureau passes certification testing, provided that the service bureau will operationally submit all initial reports, modifications and cancellations of trades. 
  • A clearing broker that uses a service bureau for its own trades and the trades of other dealers must conduct the full certification test.  The clearing broker’s certification will serve as certification for its introducing dealers.  As above, clearing brokers that have more than one interface to accept input should take care to test each interface.
  • A service bureau – i.e., a vendor that supports more than one dealer in transaction reporting – must conduct the full certification test .  The service bureau will conduct the test on behalf of at least one of its dealers.  Service bureaus that have more than one interface to accept input should take care to test on behalf of at least one dealer per interface.  Once the service bureau is fully certified, MSRB will consider its clients that are self-clearing dealers to be certified for messaging, but not for RTRS Web reporting.
  • A dealer whose agent will submit all data for a class of trades does not need to conduct certification tests for those trades.  The dealer will become certified when the agent is certified.  A dealer that will submit any data directly to RTRS to supplement submissions by its agent must conduct RTRS Web testing itself.

MSRB encourages dealers, even if not required to go through all the certification tests, to conduct testing themselves, in addition to monitoring testing done by the agent.  This is because, once testing is complete and real-time reporting is required, dealers are responsible for correct reporting of trades no matter how much testing was conducted, or by whom.  The MSRB reminds dealers that, under the amendments to Rules G-12(f) and G-14 expected to be in effect in 2005, the primary responsibility for timely and accurate submission remains with the  dealer that effects transactions.  Dealers that report trades for other dealers will also have specific responsibilities under the proposed amendments.[6]

Note that a dealer that does inter-dealer trades must be certified to report those trades to FICC’s RTTM system before submitting test messages to RTRS.  

Optional Use of RTRS Web

Dealers that are not required to conduct tests may nonetheless wish to try out the RTRS Web interface.  The Web screen will display all test trades submitted by, or on behalf of, the dealer.  Dealers may, therefore, find it useful to use the RTRS Web as a display-only method.  RTRS Web will not display operational trade data until real-time reporting is required in 2005.

Who Must Submit Form RTRS

Every dealer registered with the MSRB must complete and submit Form RTRS, even if another party conducts testing on its behalf.

Simplified Test for Low-Volume Dealers

A dealer that has averaged five or fewer trade submissions per week during the year that began July 2003 may choose a simplified submission method and, therefore, a simplified test.  For its customer trades and changes to regulatory data of its inter-dealer trades, the low-volume dealer may choose to provide all real-time input manually via the RTRS Web Browser.  Such dealers will not be involved with the “message” aspects of testing (defined in the next paragraph) and will not have to test message formatting and other message-based features.  (The dealer tests its capability to report inter-dealer trades by testing its ability to send reports of such trades to its clearing broker.  The clearing broker submits data via RTTM on behalf of the correspondent, so the correspondent does not directly test the interface with RTTM.)  

Testing that Involves Service Bureaus

Dealers may have agents, such as service bureaus, submit trade data for reporting purposes.  If a dealer uses a service bureau to submit test data, the service bureau is an agent as well.  To do this the dealer must designate the service bureau as its agent.[7]  The service bureau will contact the MSRB for an Submitter Identifier and will include this identifier in all submissions to RTRS.  (The service bureau may use the same Submitter Identifier in connection with all dealers that it assists.)

Interfaces to be Tested

RTRS has a message-based and a Web-based interface.  The message-based interface transmits SWIFT 15022 messages from and to the dealer via RTTM.  The  Web-based interface transmits data between RTRS and the dealer using a Web browser.[8]

Low-volume dealers that elect to use only the Web-based interface and that have averaged five or fewer trade submissions during the year beginning July 2003 must complete the test by December 1, 2004.  Other dealers may use both interfaces; these dealers must be prepared to test by October 1, 2004 and must either have completed testing by that date or must have scheduled testing with the MSRB by that date.

Functions Tested

The full range of RTRS functions that apply to the dealer’s business activities will be tested.  The full range of functions involves:

  • Reporting all inter-dealer trades in municipal securities[9]
  • Reporting all customer trades in municipal securities
  • Reporting trades within 15 minutes of time of trade, unless the trade has an extended reporting deadline
  • Correctly reporting, in accordance with extended reporting deadlines, certain syndicate trades, securities not traded in the previous year, short-term variable-rate securities and commercial paper.
  • Making use of the appropriate automated interfaces ( message-based, Web-based, or both)
  • Responding to error messages from RTRS by modifying or canceling erroneously reported trades
  • Correctly using reference numbers to identify trades
  • Using new data elements to report the following, if appropriate to the dealer’s business:

o “Inter-dealer regulatory-only” events[10]

o Trades done with special conditions, such as prices away from the market or trades  done “flat”

o Trades that involve an intermediate dealer and a correspondent’s correspondent,

o Trades done at the weighted average of several preceding trades

In addition to the above, specific objectives for testing correspondents (i.e., introducing dealers) are:

  • Ensuring that the correspondent and its agent communicate trade details properly[11]

  • Ensuring that the correspondent receives and understands its e-mail from RTRS

Test Customization

Not every dealer conducts the full range of activities that can be reported via RTRS.  The test procedure will be customized to fit the dealer’s anticipated business.  For example, a dealer that never trades as a member of a syndicate or selling group, and has no plans to do so, does not have to test extended deadlines for syndicate trade reporting.[12]  MSRB encourages dealers to test activities that may be added in the future, but only requires the dealer to test activities actually in use.  Any future changes in the dealer’s business activities would require additional testing.

Dealers may test major reporting components independently.  A dealer may test inter-dealer regulatory reporting at the same time it tests  customer trade reporting, or it may test the two types at separate times.

RTRS will send e-mail error messages to dealers who indicate on Form RTRS that they wish to receive them.  Dealers electing to use e-mail instead of SWIFT messages are (like other dealers) responsible to make corrections to erroneous input as soon as possible. 

Trade Date to be Used

The RTTM Test System generally uses a “current” date that is different than the true date.  To avoid receiving RTRS messages stating that test messages were submitted “late,” dealers must check the MSRB Web site (www.msrb.org) to determine the current test date and must submit test messages with this as the trade date.

MSRB Assistance During Testing

Dealers who have questions or encounter problems during testing may call the MSRB at (703) 797-6600 for assistance.  For help regarding the required content of input MT515 messages or explanation of feedback, ask for a Transaction Reporting Assistant.   To receive assistance on correctly formatting MT515 messages, ask for Denta Williams or Jason Peace.  For assistance with connectivity to RTRS Web, ask for the Technical Support group.  The Technical Support Group can be reached during business hours at (703) 797-6600 and outside of business hours at (703) 549-9505. You may also send e-mail to RTRSWebSpt@msrb.org.  (For questions regarding MQ connectivity, contact your Service Representative at NSCC.)

Test Milestones

In order to be certified as ready to report trades in real-time, a dealer must pass the following milestones.

Coordination and customization with MSRB:  The dealer must submit Form RTRS with test contact name, telephone number, e-mail address and other test-related information. Form RTRS will be available on www.msrb.org. Call a Transaction Reporting Assistant at MSRB at (703) 797-6600 after submitting the form.  During a telephone conversation, the dealer and the Assistant MSRB will plan a customized list of test trades and scenarios and will schedule test dates.  Message-based and Web-based testing will both be customized the same way.

Connectivity:  To test messaging, dealers that are NSCC participants will establish telecommunications connections to the RTTM test system.  (Note:  Dealers must contact FICC sufficiently in advance to set up the telecommunications connection.  The setup may take four to eight weeks.)  Non-NSCC participants (correspondents) must establish telecommunications connections to their clearing broker, if not already in place.  To test Web-based submission, the MSRB will make secure access to RTRS available to authorized RTRS users, as requested by the dealer on Form RTRS.

Format compliance and trade input  –  Messaging:  A dealer using messaging constructs trade messages meeting the general description of the trades in RTRS Testing Documents.xls on www.msrb.org.  For example, customer test message C-1 is specified as “buy regular way - as principal.”  The dealer must choose a CUSIP number, trade date and time, dealer symbol, dollar price, yield, capacity, etc., that represents such a trade (except for when-issued trades – see below). 

As MSRB resources permit, dealers will be able to send test messages to MSRB Transaction Reporting Assistants in text form by e-mail.  MSRB will check message formats without processing them through RTRS and will advise the dealer by e-mail or telephone of problems found.  Whether or not the dealer has messages checked by MSRB staff, the dealer must submit the required messages to RTRS.  At least one message must be submitted to RTRS within 15 minutes of the time of trade shown on the test message. 

For message-based reporting, the dealer will submit the test message to RTRS via its RTTM connection.  RTRS will check whether dealer messages comply with SWIFT and RTRS formatting rules and whether they are satisfactory as trade reports.  RTRS error messages and e-mail to the dealer will acknowledge satisfactory receipt or will describe any errors found.  (For NSCC participants, this will already have been covered to a great extent in RTTM testing of inter-dealer trades.)  In addition to RTTM tests, inter-dealer trade messages will be checked by RTRS for regulatory data.  Customer and IDRO trade messages will be checked by RTRS in their entirety.

To prepare input of when-issued trades, the dealer will use a CUSIP posted on the MSRB Web site.  This CUSIP will be in when-issued status in the MSRB security master.  MSRB will provide attributes of this CUSIP for the dealer to use in its securities master.

Format compliance and trade input – Web:  For Web-based reporting, the dealer will complete the input screen with the trade attributes.  RTRS will send feedback on the Web screen and by e-mail, as for messages.   (The status of test trades reported by message will also be shown on the dealer’s Web screen.)

Trade correction:  A list of scenarios in RTRS Testing Documents.xls on www.msrb.org. defines situations in which the dealer will report trades and then modify or cancel them using specified interfaces (message and Web screen).  Different scenarios apply to self-clearing dealers, clearing brokers, and correspondents of clearing brokers (see “Scenarios for Clearing and Introducing Dealers,” below).  As in the Format and Input part of the test, the dealer will send to MSRB the Regulatory Control Number of trades indicating “satisfactory” status after the corrections are made.

Success criteria:  When the dealer submits a satisfactory MT515 message, RTRS will return an MT509 message or an e-mail feedback marked “satisfactory” and bearing a Regulator Control Number (tag “TRRF”).  To demonstrate attainment of a milestone the dealer will inform MSRB of the External Reference Number (tag “XREF”) or the Regulatory Control Number of the test trade and the ID number of the test so that MSRB can verify completion. 

A spreadsheet called “Results Sheet” (part of RTRS Testing Documents.xls) will be available on www.msrb.org with a list of all tests.  The dealer will download the spreadsheet, insert the control numbers of its successful messages and send the spreadsheet to the MSRB to indicate its messages that are successful.  Send the spreadsheet by e-mail to RTRSCertTesting@msrb.org

Certification:  MSRB staff will verify the trades on the spreadsheet and notify the dealer that is certified for this class of trades or that there are deficiencies.  The dealer may choose to request certification at separate times for any of the trade classes (inter-dealer, IDRO and customer trades), in any order.

A dealer that has been RTRS-certified may voluntarily switch to messaging to report inter-dealer or customer trades.  The MSRB encourages dealers to convert to operational real-time reporting before the required date. Submissions in SWIFT message formats will satisfy current regulatory reporting requirements.  (RTRS Web will be available only for test purposes until 2005.  Thereafter, it will be available for operational reporting and trade display.)  A dealer using the new formats before the real-time reporting requirement becomes effective must report trades by 8:00 pm Eastern time on trade date (the closing time at RTTM for receipt of messages).  Dealers are not required to report trades in 15 minutes until the requirement goes into effect in January 2005.

Timeline

January 2005 is the RTRS operational start date.  The timeline is:

April - June 2004
Beta test period for a small number of dealers on a voluntary basis

July 2004

Test scheduling for individuals dealers begins

RTRS test environment is available to dealers

After successful tests, dealers may submit operationally using new formats

October 1, 2004

Dealers using messaging must schedule their test if not already certified

Dealers using RTRS Web for more than five trades/week (and not using messaging) must complete RTRS Web test

December 1, 2004

Dealers using RTRS Web for five or fewer trades/week must complete RTRS Web test

December 15, 2004

Deadline for all dealers to complete and pass all relevant tests

Selecting Test Dates

The MSRB and the dealer will schedule test dates together, within the deadlines.  This will level the workload for MSRB and FICC and will schedule test dates that are convenient for dealers, to the extent possible.

Testing facilities for dealers using the message-based submission method will be made available in July 2004, six months prior to the announced start-up date for RTRS operations.  Message-based submitters must be ready to test by October 1, 2004 – three months prior to the announced RTRS start-up date – and will be required to schedule test dates at that time if successful tests have not already been completed.  All message-based submitters must successfully test and be certified by December 15, 2004.

Because of the simplicity of Web-based submission, testing will not be as extensive as for message-based submission.  Submitters planning to use only the Web-based function for transaction reporting, and who currently submit an average of more than five transactions per week to the existing transaction reporting system, will be required to complete Web-based testing by October 1, 2004.[13]  Dealers with transaction volume of five or fewer trades per week must complete Web-based tests by December 1, 2004 – one month prior to the RTRS start-up date.  Testing procedures for the Web-based trade reporting function will be made available on the MSRB Web site, www.msrb.org. (As noted, these will include procedures for testing RTRS Web and for testing regulatory components of RTTM Web.)

The procedure for selecting test dates is this:

1. The dealer submits Form RTRS and indicates the time it would like to test.

2. If MSRB resources are sufficient to test the dealer at the desired time, MSRB contacts the dealer stating the expected start date (e.g., “the week of October 4”).

3. If MSRB resources are not sufficient (i.e., too many dealers already plan to start at a given time), MSRB sends an e-mail to the dealer stating an alternative time.

4. The dealer replies by e-mail, either accepting the proposed time span or stating precisely why it cannot accept the proposed change.  MSRB will determine the expected start date based on the dealer’s statement.

5. If, by the time the expected start date approaches, the dealer is not ready to test, it will contact MSRB.  MSRB and the dealer will mutually assess the situation and MSRB will determine the expected start date.

Note that, as stated above, message-based submitters must be ready to test by October 1, 2004.  If the dealer has not started testing by October 1, MSRB may assign a start date as early as Monday, October 5.  Other types of submitters must also comply with the deadlines above.

Scenarios for Self-Clearing Dealers and Clearing Brokers

Different scenarios have been defined to test the dealer’s ability to modify and cancel trade submissions.  A scenario is a set of messages involving an Instruct and one or more Modify or Cancel messages.  The dealer conducting the scenario may modify any field(s) of its choice if the field is changeable as described in the systems specification.  The dealer can choose whether to modify a trade initially submitted with an error, or to change one valid value (e.g., capacity = agent) to another (capacity = principal). 

Scenarios for a dealer that clears its own street trades and does not clear trades for correspondents will test the dealer’s ability to (1) submit Instruct messages, (2) submit Modify and Cancel messages and/or (3) use the RTTM and RTRS Web interfaces to modify and cancel regulatory data.

Scenarios for a dealer that clears its own trades and also clears trades for correspondents assume that the correspondent will submit modifications to RTRS via RTRS Web.  If the correspondent submits changes exclusively through the agent’s system and never submits data via the RTRS Web interface, these scenarios will not be used.  The clearing broker should conduct equivalent scenarios with correspondents, using its own system.  These scenarios will test the above and also (1) the ability of the correspondent and its clearing broker to report the correspondent’s street trades and (if appropriate) the correspondent’s customer trades, and (2) the ability of the correspondent to modify regulatory data submitted by its clearing broker. 

Scenarios for Correspondent Dealers

Scenarios for a correspondent dealer (i.e., introducing dealer) will test the ability of the correspondent to report and modify trades through its clearing broker, as stated in the preceding paragraph, and (if appropriate) the ability of the correspondent to report its own customer trades or to report them through a service bureau.  As noted, if the correspondent submits changes exclusively through the agent’s system and will never submit data via the RTRS Web interface, these scenarios will not be used. 

Need for Specific RTRS Testing

Clearing brokers have asked why they must test and be certified for RTRS once they are RTTM-certified.  The reason is that there are RTRS features not covered in RTTM testing.  These include:  reporting of trades with a deadline, and using the Special Price code to indicate which deadline applies (if not 15 minutes); reporting and flagging trades at prices away from the market; understanding and responding to RTRS error messages; and correctly reporting the following data elements:

Accrued interest

Capacity and contra party capacity

Correspondent and contra correspondent

Time of trade

Intermediate and contra intermediate dealer  

Special price reason code

Average weighted price indicator

Originator of message (if not sender)


ERROR CONDITIONS THAT WILL BE INCLUDED IN SCENARIOS

N913

LATE

Q111

QUEST – DP FROM Y DIFFERS FROM REPORTED DP (See Note)

Q14F

QUEST – CALCULATED ACCRUED INTEREST DOES NOT MATCH SUBMITTED ACCRUED INTEREST

U191

UNSAT – YIELD GREATER THAN DOLLAR PRICE

X01G

UNSAT – TRADE REPORT HAS DEALER XREF ALREADY IN USE

X41B

UNSAT – DEALER SYMBOL MISSING

Note:   Regarding the error message:

Q111

QUEST – DP FROM Y DIFFERS FROM REPORTED DP

This is a feature that is not part of the current Transaction Reporting System.  In RTRS, trades that are submitted with both dollar price and yield will be checked for this error.  RTRS will use the securities information in its master file, the reported yield and the trade's settlement date to calculate a dollar price.  The calculated and reported prices will be compared and prices that differ substantially will cause the trade to receive the Q111 error.

In RTRS certification, the dealer is required to submit a trade that contains this error and to modify the trade to correct it.  To submit a deliberately defective trade, the dealer could, for example, calculate the correct dollar price and yield, then deduct one dollar from the price and report the result.

A similar new feature for inter-dealer trades produces this message:

Q14F   QUEST – CALCULATED ACCRUED INTEREST DOES NOT MATCH SUBMITTED ACCRUED INTEREST

CONTENTS OF “RTRS TESTING DOCUMENTS.XLS” ON WWW.MSRB.ORG.

1. List of test trades

2. Scenarios for submitting and changing trade records

3. Results sheet for certification testing


[1] Form RTRS will be available on www.msrb.org on July 1, 2005.

[2] “Dealer” in this document denotes a broker, dealer or municipal securities dealer.

[3] MSRB filed proposed amendments  to Rules G-14 and G-12(f) on June 1, 2004.  See MSRB Notice 2004-13 on www.msrb.org.

[4] 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.

[5] 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.

[6] The proposed amendment to Rule G-14 states, “A dealer that acts as a submitter for another dealer has specific responsibility to ensure that transaction reporting requirements are met with respect to those aspects of the reporting process that are under the Submitter’s control.  A dealer that submits inter-dealer municipal securities transactions for comparison, either for itself or on behalf of another dealer, has specific responsibility to ensure that transaction reporting requirements are met with respect to those aspects of the comparison process that are under the Submitter’s control.”

[7] Dealers will designate agents on Form RTRS, which is discussed below under “Coordination with MSRB.”

[8] RTRS and RTTM each have a Web browser.  The RTTM Web browser is operated by NSCC for comparison purposes and may be used only by NSCC participants.  It may be used to report or correct both “comparison data” (CUSIP number, par, price, etc.) and “regulatory reporting data” (time of trade, etc.), if that data is associated with an inter-dealer transaction.  The RTTM Web is not available to report or correct customer or IDRO trade records.

[9] Dealers must pass RTTM tests before testing inter-dealer trade reporting with RTTM.  This is because real-time trade comparison in RTTM is a prerequisite to inter-dealer trade reporting.  Dealers are responsible to work with FICC to satisfy RTTM requirements.  For RTTM testing information, contact FICC Participant Services at (212) 855-7664.

[10] An “inter-dealer regulatory only” trade report, or “IDRO,” is a report that a fully disclosed introducing broker submitted a customer order to its clearing broker for execution, and the clearing broker executed and settled directly with the introducing broker’s customer.  Only clearing brokers will report IDROs.

[11] See, e.g., MSRB Notice 2003-23 (June 13, 2003), note 15, on www.msrb.org.

[12] For example, test messages 14.3 and 14.4 are reports of sales by a syndicate member.  These tests are marked “A,” meaning that a dealer must do them only if “Appropriate,” i.e., the dealer does syndicate sales.

[13] October 1 is the deadline for submitters that use only the Web for transaction reporting.   Submitters that initially report trades by SWIFT message and use the Web for corrections are subject to the December 15 deadline for both types of testing.