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
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.
