FAQs about Proposed Amendments to MSRB Rules Establishing Fees for Dealers and Municipal Advisors under the Rate Card Process

About the Rate Card

1. Why is the annual rate card being replaced with a 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?
5. What Happened to the previous rate card?

Proposed Fees and Credits

6. What MSRB fees are impacted by the proposed rule change?
7. Why is there a proposed credit for all market activity fees in 2026 and 2027?
8. What are the amended fee rates in the proposed rule change?
9. Why are some fees increasing or decreasing more than others?

What Happens Next

1. Why is the annual rate card being replaced with a four-year rate card?

Following substantive engagement with stakeholders over the past 18 months, MSRB is replacing the 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.  

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. When formulating a Multi-Year Rate Card, the Finance Committee and Board will consider if the rates to be established in the rate card will 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 current rate card model that included extensive engagement and outreach with stakeholders. The Board approved changes to its fee setting process in July 2025 to advance its goals of maintaining fair and equitable fees among regulated entities. 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 happened to the previous rate card?

The SEC suspended MSRB’s proposed 2024 rate card following industry feedback and concerns about the rate-setting methodology and the potential over collection of fees expressed during the SEC review process. As a result, fees were reverted to those outlined in the 2023 rate card and, in response, MSRB withdrew its proposed 2024 rate card to begin conducting extensive stakeholder outreach to solicit feedback prior to proposing the next iteration of its rate card.

6. What MSRB fees are impacted by the proposed rate card?

MSRB’s proposal would keep the rates of assessment the same as the rates currently in effect for MSRB’s Underwriting Fee, Transaction Fee, and Trade Count Fee described in MSRB Rule A-13 (collectively, the “Market Activity Fees”). Existing 2023 rates 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 projected to return surplus reserves to the industry. The credit would result in the Market Activity Fees for 2026 and 2027 to be assessed at a net rate 45% below their current levels.  

MSRB’s Municipal Advisor Professional Fee described in MSRB Rule A-11, will see an increase of $70 (approximately 6%) per year from $1,060 (2025) to $1,340 (2029) in order to maintain target contribution rates and enhance the fairness of fee burdens between broker-dealers and municipal advisors.

Proposed changes would become effective as of January 1, 2026 (or on the first day of the month following SEC approval) and remain effective for four years through December 31, 2029.

7. Why is there a proposed credit for all market activity fees in 2026 and 2027?

MSRB is proposing a temporary 45% credit on all market activity fees in 2026 and 2027 to return surplus reserves to the industry. More than $20 million of excess reserves accumulated during a period of record trading and issuance volume while 2023 fee rates remained in place following the suspension and subsequent withdrawal of MSRB’s proposed 2024 rate card.

The temporary credit reflects MSRB’s commitment to responsible fiscal stewardship and ensures that excess revenue is returned in a transparent, fair and timely manner. 

8. What are the amended fee rates in the proposed rule card?

The following proposed rates of assessment would become effective as of January 1, 2026, or on the first day of the month following SEC approval) under the proposed rule change. 

9. 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 proposed four-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 proposed 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 proposed 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.  

What Happens Next

MSRB submitted the proposed rule change to the SEC on September 30. Following publication in the Federal Register, stakeholders will have the opportunity to submit comments to the SEC on the proposed rule change during a formal comment period. MSRB welcomes stakeholder feedback and encourages continued engagement throughout the rulemaking process.