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
No comments available.
"List Offering Price" and Three-Hour Exception for Real-time Transaction Reporting: Rule G-14
The MSRB has received questions concerning the meaning of "list offering price" in Rule G-14 Real-Time Transaction Reporting Procedures. As used in this context, the term means the publicly announced "initial offering price" at which a new issue of municipal securities is to be offered to the public.
Real-time transaction reporting requires dealers to report most transactions within fifteen minutes of the time of trade execution.[1] Transactions effected at the "list offering price" by syndicate or selling group members[2] on the first day of trading in a new issue are eligible for an exception found in Rule G-14 RTRS Procedures section (a)(ii)(A). Such transactions instead are required to be reported by the end of the day. Note that syndicate and selling group members are not required to wait to report such transactions at the end of the day and may choose to report prior to the end of the day.
The exception from fifteen-minute transaction reporting for list-price syndicate trades is based on operational difficulties that otherwise might be presented for dealers when large numbers of transactions at the initial offering price must be reported by a dealer at one time. The MSRB viewed these operational considerations as sufficiently important to allow trades to be reported at the end of the day given that the price of such trades (the "list offering price") is public. Note that transactions by syndicate or selling group members at prices other than the "list offering price" on the first day of trading in a new issue are required to be reported within fifteen minutes of the time of trade execution. For example, transactions between the syndicate manager and syndicate members ("takedown" transactions) that are at prices other than the "list offering price" must be reported within fifteen minutes of the time of execution. Similarly, transactions done at offering prices that have not been publicly announced, e.g. "not reoffered" prices, also must be reported within fifteen minutes of the time of execution since these prices are not public.
Questions also have been asked about the availability of the three-hour trade reporting exception found in Rule G-14 RTRS Procedures section (a)(ii)(C). When a dealer effects a trade in an issue it has not traded in the past year and does not have CUSIP numbers and indicative data for the issue in its securities master file used to process trades for confirmations, clearance and settlement, it is allowed three hours to report.[3] This exception is designed to allow a dealer time to set-up a security it has not traded and is available for transactions on the first day of trading in a new issue. Note this exception is not available for syndicate and selling group members.
[1] Rule changes to MSRB Rules G-14, on transaction reporting, and G-12(f), on automated comparison of inter-dealer transactions, that will require dealers to report transactions in real-time become effective January 31, 2005. See MSRB Notice 2004-36 (November 17, 2004) on www.msrb.org.
[2] References to "syndicate and selling group members" in this context are meant to include managers of syndicates as well as sole underwriters or placement agents in non-syndicated offerings.
[3] The three-hour exception sunsets one year after real-time transaction reporting is implemented.
