FAQs about New Multi-Year Rate Card Fees for Dealers and Municipal Advisors

About the Rate Card

1. Why was the previous annual rate card model replaced with the new four-year rate card?
2. What is the Multi-Year Rate Card Process?
3. How will the Multi-Year Rate Card be used to manage the reserves and mitigate rate changes?
4. Why did the MSRB establish the Multi-Year Rate Card Process?

New Fees and Credits

5. What MSRB fees are impacted by the new Multi-Year Rate Card?
6. Why is there a credit for dealers' Market Activity Fees in 2026 and 2027?
7. What are the new fee rates under the Multi-Year Rate Card?
8. Why are some fees increasing or decreasing more than others?

1. Why was the previous annual rate card model replaced with the new four-year rate card?

Following substantive engagement with stakeholders, MSRB replaced the previous annual rate card process with a Multi-Year Rate Card. This longer-term approach reflects feedback from stakeholders who expressed a need for a more predictable fee structure than under an annual process.  

The Multi-Year Rate Card Process provides greater transparency, stability and certainty in fees for regulated entities, and allows them to better forecast their regulatory costs and reduce the administrative burden of annual rate changes. It maintains an appropriate balance of assessments between regulated entities and allows MSRB to manage organizational reserves responsibly.  

2. What is the Multi-Year Rate Card Process?

The Multi-Year Rate Card Process allows MSRB to adjust the rates of assessment for the Market Activity Fees under MSRB Rule A-13 and the Municipal Advisor Professional Fee under MSRB Rule A-11 using a process that provides predictability and stability for MSRB’s regulated entities. It enables MSRB to better align its revenues with long-term needs, manage organizational reserves and mitigate volatility in market activity.  

3. How will the Multi-Year Rate Card be used to manage reserves and mitigate rate changes? 

The purpose of the Multi-Year Rate Card is to manage organizational reserves at target levels through periodic rate adjustments. MSRB aims to mitigate the degree of rate adjustments that may occur from year to year within a Multi-Year Rate Card by limiting annual rate adjustments to 15% above or below the prior year’s rate. In formulating the current and future Multi-Year Rate Cards, the Finance Committee and Board will consider if the rates to be established in the rate card appropriately balance organizational reserves within +/- 20% of its target levels over the effective period of the rate card.  

In an extraordinary circumstance where MSRB’s reserves are above 20% of its target levels during the lifetime of an effective Multi-Year Rate Card, MSRB may evaluate reasonable methods to reduce reserves levels, including temporary rate reductions for certain fees. If a temporary rate reduction for certain fees is utilized to reduce reserves levels, then the degree of reduction in rates may be in excess of the 15% threshold for annual rate changes.  

4. Why did the MSRB establish the Multi-Year Rate Card Process?

In response to stakeholder concerns and to advance its commitment to financial stewardship, MSRB’s Board of Directors conducted a retrospective review of its then-current rate card model that included extensive engagement and outreach with stakeholders. To advance its goals of maintaining fair and equitable fees for regulated entities, the Board approved changes to its fee setting process in July 2025, filed the new fee setting process and new Rate Card Fees with the Securities and Exchange Commission (SEC) in October 2025, and received SEC approval in December 2025. The Board also strived to reduce reserve targets, while ensuring that MSRB has sufficient revenue and organizational reserves to maintain its operations without interruption, even in economic downturns and other unforeseen circumstances. This new approach of a Multi-Year Rate Card Process allows the organization to more effectively and efficiently manage its funding and reserve levels needed to fulfill its statutory mandate over the long-term, while balancing stakeholder concerns around volatility.

5. What MSRB fees are impacted by the new Multi-Year Rate Card?

The new Multi-Year Rate Card is effective as of January 1, 2026, and remains effective for four years through December 31, 2029. The Multi-Year Rate Card keeps the rates of assessment the same as the rates that had been in effect since October 1, 2022, for MSRB’s Underwriting Fee, Transaction Fee, and Trade Count Fee under MSRB Rule A-13 (collectively, the “Market Activity Fees”), which will remain in place through 2029 with no fee increase. Additionally, a temporary 45% credit for all market activity fees in 2026 and 2027 is designed to return surplus reserves to the industry. The credit will result in the Market Activity Fees for 2026 and 2027 to be assessed at a net rate that is 45% below levels assessed since October 2022.  

MSRB’s Municipal Advisor Professional Fee under MSRB Rule A-11 will see an increase of $70 (approximately 6%) per year from $1,060 in effect since October 1, 2022, beginning at $1,130 in 2026 to $1,340 in 2029, in order to maintain target contribution rates and enhance the fairness of fee burdens between broker-dealers and municipal advisors.

6. Why is there a credit for dealers' Market Activity Fees in 2026 and 2027?

MSRB established a temporary 45% credit on Market Activity Fees in 2026 and 2027 to return surplus reserves to the industry. Excess reserves accumulated during a period of record trading and issuance volume under the prior annual rate card and during the process of redesigning the rate setting process, which involved extensive industry outreach and obtaining SEC approval. The new Multi-Year Rate Card process is designed to avoid excess reserves in the future, and the temporary credit reflects MSRB’s commitment to responsible fiscal stewardship, ensures that excess revenue is returned in a transparent, fair and timely manner, and resets MSRB reserves to an appropriate level. 

7. What are the new fee rates under the Multi-Year Rate Card?

The following rates of assessment are effective as of January 1, 2026:

8. Why are some fees increasing or decreasing more than others?

In 2022, as part of its previous annual rate card process, MSRB established targets for relevant contribution of revenue from the various rate card fees. In the new Multi-Year Rate Card, MSRB is maintaining the target contributions of 92% of rate card revenue from Market Activity Fees and 8% from Municipal Advisor Professional Fees. The rates for the Municipal Advisor Professional Fee are designed to achieve a target of generating 8% of total rate card revenue from that fee by 2029. To increase stability and predictability, the Municipal Advisor Professional Fee increases are the same dollar amount ($70) each year during the four years 2026 – 2029.  

The Temporary Credits in 2026 and 2027 only apply to Market Activity Fees and not to Municipal Advisor Professional Fees because MSRB’s excess reserves resulted from revenue from Market Activity Fees during a period of record trading and issuance volume and not from excess Municipal Advisory Professional Fees.