Select regulatory documents by category:
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated April 10, 2012
2. Full Life Financial LLC: Letter from Keith Newcomb, Portfolio Manager, dated April 14, 2012
3. Government Finance Officers Association: Letter from Susan Gaffney, Director, Federal Liaison Center, dated April 6, 2012
4. Kious and Co.: E-mail from Michael Kious dated March 13, 2012
5. M. E. Allison & Co., Inc.: Letter from Christopher R. Allison, Chief Financial Officer, dated March 13, 2012
6. McGuirk, Hugh: E-mail dated March 14, 2012
7. National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated April 9, 2012
8. Oppenheimer & Co. Inc.: Letter from Allison F. Fleitas II, Managing Director, Municipal Capital Markets Group
9. UMB Bank, N.A.: E-mail from Kristin Koziol dated March 30, 2012
1. Alamo Capital: E-mail from Bill Mullally dated March 9, 2012
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated April 13, 2012
3. CFA Institute: Letter from Kurt N. Schacht, Managing Director, Standards and Financial Market Integrity, and James C. Allen, Head, Capital Markets Policy, dated April 13, 2012
4. Edward D. Jones & Co., L.P.: Letter from David E. Fischer-Lodike, Capital Markets and Operations Compliance, dated April 13, 2012
5. Full Life Financial LLC: Letter from Keith Newcomb, Portfolio Manager, dated April 13, 2012
6. Government Finance Officers Association: Letter from Susan Gaffney, Director, Federal Liaison Center, dated April 13, 2012
7. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel-Securities Regulation, dated April 13, 2012
8. Li, Richard: Letter dated March 7, 2012
9. Melton, Chris: E-mail dated April 13, 2012
10. National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated April 13, 2012
11. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated April 13, 2012
12. Thornburg Investment Management: Letter from Josh Gonze, Chris Ryon, and Chris Ihlefeld, Co-Portfolio Managers, dated March 12, 2012
13. Vanguard: Letter from Christopher Alwine, Head of Municipal Bond Group, dated April 13, 2012
14. Wells Fargo Advisors: Letter from Ronald C. Long, Director of Regulatory Affairs, dated April 13, 2012
1. Broadridge Financial Solutions, Inc.: Letter from Charles V. Callan, Chief Regulatory Officer, dated April 2, 2012
2. College Savings Foundation: Letter from Roger Michaud, Chairman, dated April 2, 2012
3. College Savings Plans Network: Letter from Michael L. Fitzgerald, Chair, College Savings Plans Network, & State Treasurer of Iowa, dated April 2, 2012
4. Commonwealth Financial Network: Letter from Brendan Daly, Legal and Compliance Counsel, dated March 30, 2012
5. Consumer Federation of America: Letter from Barbara Roper, Director of Investor Protection, dated May 7, 2012
6. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated April 2, 2012
7. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated April 2, 2012
8. Sutherland Asbill & Brennan LLP: Letter from Michael Koffler dated April 2, 2012
9. T. Rowe Price Associates, Inc.: Letter from David Oestreicher, Chief Legal Counsel, and Regina M. Watson, Senior Associate Counsel, dated April 2, 2012
10. Utah Educational Savings Plan: Letter from Lynne N. Ward, Executive Director, dated April 2, 2012
11. Virginia College Savings Plan: Letter from Mary G. Morris, Chief Executive Officer, dated April 2, 2012
1. BondView: Letter from Robert Kane, CEO, dated March 5, 2012
2. Government Finance Officers Association: Letter from Susan Gaffney, Director, Federal Liaison Center, dated March 9, 2012
3. Haynsworth Sinkler Boyd, P.A.: Letter from Kathleen Crum McKinney and Theodore B. DuBose, dated March 5, 2012
4. Ice Miller LLP: Letter from Philip C. Genetos dated March 6, 2012
5. Indiana Housing & Community Development Authority: Letter from Blake A. Blanch, Chief Financial Officer
6. Indianapolis Airport Authority: Letter from Joseph R. Heerens, Chief Legal Officer, dated March 6, 2012
7. Los Angeles County Metropolitan Transportation Authority: Letter from Michael J. Smith, Assistant Treasurer
8. National Association of Bond Lawyers: Letter from Kristin H.R. Franceschi, President, dated March 8, 2012
9. National Federation of Municipal Analysts: Letter from Lisa Good, Executive Director, dated March 26, 2012
10. Squire Sanders LLP: Letter dated March 6, 2012
Transaction Reporting of Multiple Transactions Between Dealers in the Same Issue: Rules G-12(f) and G-14
The MSRB has become aware of problems in transaction reporting as a result of dealers "bunching" certain inter-dealer transactions in the comparison system. Recently, some dealers have reported the sum of two trades as one transaction in instances when two dealers effected two trades with each other in the same issue and at the same price. When two transactions are effected, two transactions should be reflected in each dealer's books and records and two transactions are required to be reported to the MSRB. The time of trade for each transaction also must accurately reflect the time at which a contractual commitment was formed for each quantity of securities. For example, if Dealer A purchases $50,000 of a municipal issue at a price of par from Dealer B at 11:00 am and then purchases an additional $50,000 at par from Dealer B at 2:00 pm, two transactions are required to be reflected on each dealers' books and records and two transactions are required to be reported to the MSRB.
Since the same inter-dealer trade record submitted for automated comparison under Rule G-12(f) also is used to satisfy the requirements of Rule G-14, on transaction reporting, each inter-dealer transaction should be submitted for automated comparison separately in order to comply with Rule G-14's requirement to report all transactions. Failure to do so causes erroneous information concerning transaction size and time of trade to appear in the transparency reports published by the MSRB as well as in the audit trail used by regulators and enforcement agencies. To the extent that dealers use the records generated by the comparison system for purposes of complying with MSRB Rule G-8, on recordkeeping, it may also create erroneous information as to the size of transactions effected or time of trade execution.
