Select regulatory documents by category:
Dealers, General Public, Investors, Issuers, Municipal Advisors
All Comments to Notice 2024-15
- ABLE Savings Plan Network: Letter from Bette Ann Mobley, Chair, dated April 10, 2025
- AKF Consulting Group: Letter from Andrea Feirstein, Managing Director, and Mark Chapleau, Senior Consultant, dated April 11, 2025
- Arizona State Treasurer’s Office: Letter from Kimberly Yee, Treasurer, dated April 10, 2025
- Ascensus: Letter from Christal Fenton, Associate General Counsel, dated April 10, 2025
- Bank of North Dakota: Email from James Barnhardt dated April 3, 2025
- College Savings Foundation: Letter from Chris McGee, Chair, dated April 9, 2025
- College Savings Plans Network: Letter from Mary G. Morris, Chair, dated April 2, 2025
- Commonwealth Savers Plan: Letter from Mary G. Morris, Chief Executive Officer, dated April 11, 2025
- First Public, LLC: Email from Bill Mastrodicasa dated April 11, 2025
- Government Finance Officers Association: Letter from Emily Brock, Director of Federal Liaison Center, dated June 3, 2025
- Illinois State Treasurer’s Office: Letter from Michael W. Frerichs, Treasurer, dated April 10, 2025; and Letter from Michael Frerichs, Treasurer, dated April 10, 2025
- Investment Company Institute: Letter from Tara Buckley, Deputy General Counsel, Financial Regulation, and Shannon Salinas, Associate General Counsel, Retirement Policy, dated April 11, 2025
- Massachusetts Educational Financing Authority: Letter from Thomas M. Graf, Executive Director, dated April 9, 2025
- my529: Letter from Richard K. Ellis, Executive Director, dated March 31, 2025
- Nebraska State Treasurer’s Office: Letter from Rachel Biar, Deputy State Treasurer for Savings Programs, dated April 2, 2025
- Pennsylvania Treasury Department: Letter from Stacy Garrity, Treasurer, dated April 2, 2025
- Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Gerald O’Hara, Vice President and Assistant General Counsel, dated April 11, 2025
- TIAA-CREF Tuition Financing, Inc: Letter from Christopher S. Lynch, President, dated April 10, 2025
- Vestwell: Letter from Aaron Schumm, Chief Executive Officer, dated April 11, 2025
Dealers, General Public, Municipal Advisors
All Comments to Notice 2024-14
- American Securities Association: Letter from Jessica R. Giroux, General Counsel and Head of Fixed Income Policy, dated January 28, 2025
- Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated January 28, 2025
- ICE Bonds Securities Corporation: Letter from Robert Laorno, General Counsel, dated January 21, 2025
- National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 28, 2025
- Public Resources Advisory Group, Inc.: Letter from Thomas F. Huestis, Senior Managing Director, dated January 27, 2025
- Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Gerald O’Hara, Vice President and Assistant General Counsel, dated January 28, 2025
Dealers, General Public, Investors, Issuers, Municipal Advisors
Dealers, General Public, Investors
Dealers, General Public, Investors
All Comments to Notice 2024-09
- Association of Registration Management, Inc.: Letter from Richard Izzo, President, dated August 5, 2024
- Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated August 5, 2024
- Frost Bank Capital Markets Division: Letter from Jeff Beckel, SEVP and Director of Capital Markets, dated July 30, 2024
- Frost Bank Capital Markets Division: Email from Trevor Cross dated July 30, 2024
- Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, Head of Municipal Securities, dated August 5, 2024
Dealers, General Public, Investors, Issuers
Bank Dealers, Dealers, General Public, Investors
Dealers, General Public, Investors, Issuers
Municipal Advisors
Dealers, Municipal Advisors
Dealers, Municipal Advisors
Executing Broker Symbols: Rule G-14
MSRB Rule G-14 on Transaction Reporting requires that every dealer obtain an executing broker symbol, if one has not already been assigned, from National Association of Securities Dealers Automated Quotations (NASDAQ). NASDAQ will assign executing broker symbols to all dealers including bank dealers. NASDAQ Subscriber Services can be reached at 212-231-5180, option 3. When calling NASDAQ Subscriber Services for an executing broker symbol, dealers should state that they need the symbol for use in reporting transactions in municipal securities to the MSRB. If dealers experience difficulties in obtaining executing broker symbols, then they can send an e-mail to subscriber@NASDAQ.com.
NOTE: This notice was revised to reflect updated information.
Review and Approval of Customer Accounts
Review and approval of customer accounts. This is in response to your letter dated July 24, 1996, requesting an interpretation of rule G-27(c)(iii) on written supervisory procedures.
Rule G-27(c)(iii) requires that each municipal securities dealer adopt, maintain and enforce written supervisory procedures ensuring the "regular and frequent" review and approval by a designated principal of customer accounts introduced or carried by the dealer in which transactions in municipal securities are effected. The rule further states that such review shall be designed to ensure that such transactions are in accordance with all applicable rules and to detect and prevent irregularities and abuses.
Because circumstances vary from dealer to dealer, the Board has not specified a time period to define "regular and frequent" for purposes of rule G-27(c)(iii). As you can see, however, the purpose of this provision is to detect and prevent irregularities and abuses that may occur in customer accounts. The Board expects dealers to establish procedures that effectively obtain this objective and that are capable of compliance. While the Board has never specifically addressed "risk-focussed" methods for determining periodic account review, the Board has stated that, in determining when an account must be reviewed, a dealer might look to the volume and frequency of trading and the nature of the securities traded. The Board noted that account review guidelines based on these factors would be appropriate if they are articulated clearly in a dealer's written supervisory procedures.[1] MSRB interpretation of August 7, 1996.
[1] Supervision Requirements, MSRB Reports, Vol. 10, No. 2 (May 1990) at 6.
Rule G-14 Transaction Reporting Procedures-Time of Trade Reporting
1. Q: When is the inter-dealer time of trade reporting requirement effective?
A: The amendment to the rule G-14 transaction reporting procedures requiring the submission of time of trade execution for inter-dealer transactions became effective on July 1, 1996.
2. Q: What is the purpose of submitting the time of trade to the Board?
A: The Board's Transaction Reporting Program has two functions - public dissemination of price and volume information about frequently traded securities and the maintenance of a surveillance database to assist regulators in inspection for compliance with, and enforcement of, Board rules and securities laws. The surveillance database includes, among other things, the price and volume of each reported transaction, the trade date, the identification of the security traded, and the parties to the trade. The addition of the time of trade execution will enable the enforcement agencies to construct audit trails of inter-dealer transactions. When customer transactions are added to the system in 1998, these transaction records also will include time of trade. Time of trade will not be made public.
3. Q: How is time of trade reported?
A: Under rule G-14, inter-dealer transaction information is reported to the Municipal Securities Rulemaking Board using the same system used for automated comparison of inter-dealer transactions, operated by National Securities Clearing Corporation. Rule G-14 requires that the transaction information be submitted in the format specified by NSCC, and within such timeframe as required by NSCC to produce a compared trade for the transaction in the initial comparison cycle on the night of trade date. A broker, dealer or municipal securities dealer may employ an agent that is a member of NSCC or a registered clearing agency for the purpose of submitting transaction information. For example, the clearing broker generally reports transactions to the MSRB through NSCC when there is an introducing/clearing broker arrangement.
Under the new amendment to rule G-14, the transaction information submitted in accordance with the rule G-14 procedures must include the time of trade execution. NSCC has provided a space designated for this purpose in the standard format used for submitting trade data into the automated comparison system.
4. Q: Which dealer in an inter-dealer transaction reports the time of trade?
A: Under NSCC's automated comparison procedures, both sides of a transaction generally are required to submit transaction information. Therefore, time of trade will be reported by each side of the transaction in most cases. For "syndicate take-down" transactions, which are reported by only the seller, the time of trade is reported only by the seller.
5. Q: If the time of trade that I submit does not agree with the time of trade that the contra party submits, will this cause the trade not to compare?
A: No. The time of trade is not a match item in the automated comparison system.
6. Q: Why do both sides to the transaction have to submit the time of trade?
A: In some cases, even though both sides of a transaction are supposed to submit transaction information, the Board receives transaction information from only one party to a transaction. This may occur, for example, when a dealer "stamps an advisory" to create a compared trade. It therefore is necessary for each side of a transaction to report the time of trade to ensure that the surveillance data base has at least one report of the time of trade.
7. Q: Does the time of trade reporting requirement apply only to secondary market transactions?
A: No. The time of trade is required for all inter-dealer transactions including those in the primary market.
8. Q: How does a dealer determine the time of trade for transactions?
A: In general, this is the same time as the "time of execution," as currently required for recordkeeping purposes under rule G-8(a)(vi) and (vii).
9. Q: What is the time of trade for syndicate allocations on new issues?
A: First it should be noted that the "initial trade date" for an issue of municipal securities cannot precede the date of award (for competitive issues) or the date that the bond purchase agreement is signed (for negotiated issues). See rule G-34(a)(ii)(C)(2) and MSRB Interpretations of April 30, 1982, MSRB Manual and October 7, 1982, MSRB Manual. Similarly, the time of trade may not precede the time of award (for competitive issues) or the time that the bond purchase agreement is signed (for negotiated issues). In the typical case involving a competitive issue in which allocations are made after the date of award, the time of trade execution is the time that the allocation is made. If allocations have been "preassigned," prior to a competitive award, or prior to the signing of a bond purchase agreement, the time of award or signing of the bond purchase agreement should be entered as the "time of trade."