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Bank Dealers, Dealers, Municipal Fund Securities
Bank Dealers, Dealers, Municipal Advisors
1. Americans for Financial Reform; American Federation of State, County and Municipal Employees; and Consumer Federation of America: Letter dated July 13, 2015
2. Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated July 20, 2015
3. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel--Securities Regulation, dated July 13, 2015
4. Jay M. Goldstone: Letter dated July 10, 2015
5. Jerry Gold: Letter dated July 17, 2015
6. Lamont Financial Services Corporation: Letter from Bob Lamb, President, dated July 7, 2015
7. Loews Corporation: Letter from Mark G. Muller dated July 1, 2015
8. National Association of Municipal Advisors: Letter from Terri Heaton, President, dated July 13, 2015
9. National Federation of Municipal Analysts: Letter from Lisa S. Good, Executive Director, dated July 13, 2015
10. Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated July 13, 2015
11. Robert E. Rutkowski: E-mail dated July 13, 2015
12. Robert Zubak: Letter dated July 6, 2015
13. Samson Capital Advisors: Letter from Benjamin S. Thompson, Managing Principal and Chief Executive Officer, dated July 7, 2015
14. Securities Industry and Financial Markets Association: Letter from Michael Decker, Managing Director, dated July 13, 2015
15. Wells Capital Management Incorporated: Letter from Gilbert L. Southwell III, Vice President, dated July 8, 2015
Bank Dealers, Dealers, Municipal Advisors
Municipal Advisors
Bank Dealers, Dealers, Municipal Advisors
Bank Dealers, Dealers, Municipal Advisors
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.
