FACILITY FOR SHORT-TERM OBLIGATION RATE TRANSPARENCY SYSTEM – SHORT

MUNICIPAL SECURITIES RULEMAKING BOARD
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 about securities bearing interest at short-term rates and making such information publicly available through a dissemination service. 

Submissions to the SHORT System

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

Information to be Submitted.  The basic items of information 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).  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.  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).  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.  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.

Method of Submission.  Information 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.  Computer-to-computer submissions utilize XML files.  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.

SHORT System Processing

The SHORT System performs various data checks to ensure that information submitted is 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 submitted on their behalf by either an ARS Auction Agent or a Designated Agent are able to monitor such information submissions. 

SHORT System Data Dissemination

Information submitted to the SHORT System that passes the format and data checks described above is processed and disseminated on a real-time basis.  Any changes to submissions also are processed upon receipt and updated information is 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.  The MSRB plans to offer subscriptions to the information submitted to the SHORT System in the future.