by Ernesto Lanza, MSRB Chief Regulatory and Policy Officer
October 2025
The municipal securities market has changed significantly since MSRB was established 50 years ago—and our rulemaking process has remained steady, providing a stable foundation to adapt MSRB rules to meet the market’s evolving needs. While the market has grown more complex, MSRB’s commitment to transparent, inclusive, and economically sound rulemaking remains.
While the rule writing process may seem complicated, we want to ensure all market participants understand how the process works and how stakeholders inform our work and decisioning. At the end of the day, MSRB’s north star continues to be our congressional mandate to protect investors, issuers and the public interest. Together with our technology and data, MSRB’s rules contribute to this critically important mission that ensures a fair and efficient municipal market, which benefits our nation’s communities.
Each MSRB rule starts by identifying a market need, often aided by collaboration with stakeholders and fellow regulators, and assessing whether regulatory action is the best path forward. In some cases, MSRB may issue a concept release or Request for Information to explore an issue more broadly and receive valuable and varied stakeholder feedback prior to drafting a proposal.
When rulemaking is warranted, MSRB begins drafting new or amended rules to address the market need. This phase is informed by a formal economic analysis to assess the potential implications of possible approaches to addressing market issues. Depending on the significance of the change, MSRB will publish a Request for Comment so those we are congressionally mandated to protect—investors, issuers and the public—as well as those we regulate—dealers and municipal advisors—have an opportunity to provide feedback. This feedback is crucial to ensuring that our rules are tailored and effective. It also helps us determine whether deeper economic analysis or further Requests for Comment are needed before proceeding, or whether no rulemaking should be undertaken.
Once MSRB concludes that a proposed rule appropriately balances competing considerations and represents the best approach to address the underlying issue, it is filed with the Securities and Exchange Commission (SEC). The SEC will have a comment period for our proposed rules, providing yet another opportunity for the industry and public to provide feedback. In general, a rule does not take effect until the SEC approves it. If the rule is not immediately effective, MSRB will set an effective date, taking into consideration the time, cost, and labor that may be required to comply. Read more about each step of the process for additional detail.
While it is easy to assume the rulemaking process is over when the rule takes effect, MSRB’s role doesn’t end there. We monitor the market, engage with stakeholders and evaluate whether our rules are achieving their intended purpose. This ongoing review process helps us adapt to new developments, ensure our rulebook reflects current market practices and protects investors, issuers and the public interest.
