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Muni Price Reporting (TRS)MSRB Speaks on Transaction ReportingUser's Manual for Customer Transaction ReportingPreparing to Submit Customer Trade DataBroker SymbolAny dealer that effects a transaction in municipal securities (either with other dealers or with customers) must obtain and use an identifying symbol so that the MSRB knows the dealer is responsible for the transaction with respect to customer protection issues such as suitability and disclosure of material facts to the customer. Note that, if an introducing broker/clearing broker relationship exists whereby the introducing broker induces a transaction, takes an order for transactions from a customer, or recommends a transaction to a customer and passes the customer transaction information to the clearing broker, then the introducing broker's symbol should be listed on the transaction record. (In the inter-dealer system, the field designated by NSCC for this identifier is the field for "executing broker." Therefore, in many MSRB documents, the symbol is referred to as an "executing broker symbol.(1)") The broker symbol is a four-letter combination (such as "ABCD") assigned to the dealer by the NASD. It serves to identify the dealer to the MSRB and other regulators. Within the Transaction Reporting System, the broker symbol is essential for the construction of an accurate audit trail. Again, note that in both the inter-dealer and customer systems, this symbol identifies the dealer that actually effected the transaction (in contrast to the dealer who submitted the trade information, or who cleared the trade). Although NSCC may have assigned your firm an NSCC clearing number (such as "1234"), you may not use the clearing number to identify your customer trades to the MSRB. You must use the four-character alphabetic symbol, because it is the standard identifier used in the surveillance database and audit trail. The trade reporting specifications (Appendixes D, E and H) describe where to place the broker symbol in customer trade reports, and NSCC's specifications do the same for inter-dealer trade reports. Each dealer must use its own symbol - it may not use the symbol of the dealer or service bureau that clears for it or submits data on its behalf. Obtaining a SymbolIf your firm does not have an NASD-assigned symbol and you are a direct participant in NSCC's automated comparison system or a correspondent of a direct participant, please call your NSCC representative to obtain a symbol. For further details, please see NSCC's Important Notice dated October 9, 1998. If your firm is neither a direct participant in NSCC's automated comparison system nor a correspondent of a direct participant, obtain an NASD-assigned symbol by calling NASD Subscriber Services at (800) 777-5606 and explain that you need a symbol for reporting municipal securities transactions. Note that the NASD will assign symbols to bank dealers even though they are not NASD members. Bank dealers should specifically mention the purpose for which they need a symbol when talking with NASD staff. Transaction Reporting Information FormThe MSRB needs basic information about each dealer before the dealer can report its customer transactions. Among other things, we need this information to verify that both the MSRB and the dealer agree on the dealer, firm or bank's correct name and broker symbol. If your firm has not already done so, provide us with the required information by completing the Transaction Reporting Information Form, which is found in Appendix C. Every dealer registered with the MSRB must send a Transaction Reporting Information Form to the MSRB, even if it does not do municipal securities transactions. A place is available on the form for stating that the firm does not do such transactions.
Submitter IDAs described below, you have a choice of methods for reporting customer trades to the MSRB -you may submit electronic files of trade data or you may have another party submit files on your behalf. Files must be identified with a submitter ID, in addition to having a broker symbol on each trade. If you, as a dealer, submit files yourself, you must have a "submitter ID" to identify those files to the system. You must use a submitter ID whether you submit files through NSCC or by personal computer directly to the MSRB. MSRB transaction reporting assistants typically can assign your firm a submitter ID during a brief telephone conversation. Call the MSRB at (703) 797-6600 to obtain a submitter ID. You (or the party reporting on your behalf) must have been assigned a submitter ID by MSRB in order to report customer trades in compliance with rule G-14. Data and File SpecificationsThe most important part of preparation for customer transaction reporting is to become familiar with the requirements for transaction data. Following are the data elements that must be reported for each trade (see Appendix D for definitions): CUSIP number If another party produces customer trade files on your behalf, you need only become familiar with the definitions of the above data elements and understand how to use them - for example, how many digits to use and how to identify purchases and sales. If you are planning to produce your own files by extracting data from your existing record-keeping system, you need to completely understand the file specifications in Appendixes D, E and H in order to format the file correctly. Note that you may obtain personal computer software from the MSRB, as described in the next chapter, with which you may key in transaction data. Given the correct input data, the PC software will construct and transmit a properly formatted file to the MSRB.
Testing With the MSRBTo ensure that the CTRS can process the trade data you provide, you must test with the MSRB before reporting any trades, by submitting files of trade data to the CTRS for several days. TRS will send you error reports during the test period that will inform you whether your files are in the correct format or how they must be changed. To test, call (703) 797-6600 and ask for the Transaction Reporting System help desk. Tell the help desk staff that you would like to test customer transaction reporting. See also the June 1998 Questions and Answers nos. 58-62. Note that, to test your system with CTRS for any reason before your first report of trades or when implementing any change in your system you must speak to the help desk staff and you must mark your files as test files. These two steps are necessary to prevent your test data from going into the surveillance database.
Testing With the NSCC If you are submitting files via the NSCC, you must test with the NSCC in addition to testing with the MSRB. NSCC testing procedures are given in Appendix I. | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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