Select regulatory documents by category:
Bank Dealers, Dealers, Investors, Issuers, Municipal Advisors
Applicability of Trade Reporting for Certain Allocations to Customer Accounts By Dually-Registered Broker-Dealers/Investment Advisers
Applicability of Trade Reporting for Certain Allocations to Customer Accounts By Dually-Registered Broker-Dealers/Investment Advisers1
[Th]e MSRB acknowledges that in certain circumstances a customer allocation may be subject to trade reporting under Rule G-14. However, the MSRB observes that in the case of a purchase of a block order by a dually registered dealer/investment adviser (“BD/IA firm”) of municipal securities that are then allocated internally to advisory accounts at the same price as the block order (i.e., without transaction-based compensation, such as with a non-transaction-based wrap or similar advisory fee), the MSRB historically has only required that the original block order be reported and not the subsequent related allocations to customers in advisory accounts where, with respect to any such allocation, the BD/IA firm is acting as an investment adviser to such account directing an internal delivery of a portion of such block of municipal securities acquired by the BD/IA firm to the advisory account.2 This treatment would continue based on the core principle that, as a price transparency system, RTRS seeks to disseminate publicly only such pricing information that is indicative of market prices and not price information that may not reliably reflect such market prices. The MSRB believes that publishing price information for smaller customer allocations that were priced based on the larger block price of the original block trade is not only unlikely to be indicative of market prices, but could also be misleading.3
1Excerpt from Letter to Secretary, Securities and Exchange Commission, from Ernesto A. Lanza, Chief Regulatory and Policy Officer, MSRB, dated September 5, 2025, at 5–6, available at https://www.msrb.org/sites/default/files/2025-09/SR-MSRB-2025-01-MSRB-Response-to-Comments_0.pdf (internal citations renumbered). See also Securities Exchange Act of 1934 (“Exchange Act”) Release No. 103987 (Sept. 16, 2025), File No. SR-MSRB-2025-01, 90 FR 45274, 45277 nn.58–60 and accompanying text (Sept. 19, 2025).
2See, e.g., Exchange Act Release No. 74564 (Mar. 23, 2015), 80 FR 16466, 16466 n.4 (Mar. 27, 2025), File No. SR-MSRB-2015-02 (“RTRS serves as an audit trail for municipal securities trading, with the exception of certain internal movements of securities within dealers that currently are not required to be reported”). See also MSRB Notice 2008-19, MSRB Seeks Comment on the Reporting of Proprietary Desk Transactions under Rule G-14, on Reports of Sales or Purchase (Apr. 11, 2008) (the “Prop Desk RFC”) (“Currently, internal movements of securities within a dealer organization are not considered to be reportable under Rule G-14.”). In the Prop Desk RFC, the MSRB proposed potentially requiring reporting to RTRS internal movements between a dealer’s proprietary desk and another part of the same dealer firm. The MSRB determined not to establish such a requirement with respect to such internal movements and continued to adhere to its position that internal movements are not reportable to RTRS. Of course, while the allocation is not reportable, the BD/IA firm would be subject to the full panoply of investment adviser duties, including a fiduciary duty to its customer, when it acts in this capacity as an investment adviser with respect to the customer’s advisory account.
3See, e.g., MSRB Notice 2003-20, Notice on Reporting and Comparison of Certain Transactions Effected by Investment Advisors: Rules G-12(f) and G-14 (May 23, 2003) (discussing the appropriateness of reporting only the price of the single block order trade with a third-party investment adviser rather than individual smaller transfers and allocations directed by such adviser that would be reportable at the same price as the block trade).
Bank Dealers, Dealers, General Public, Investors
Bank Dealers, Dealers, Municipal Advisors
1. American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated February 7, 2013
2. Cooperman Assoc.: E-mail from Josh Cooperman dated December 18, 2012
3. Financial Information Forum: Letter from Arsalan Shahid, Program Director, dated February 19, 2013
4. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated February 19, 2013
5. FirstSouthwest: Letter from Hill A. Feinberg, Chairman and Chief Executive Officer, and Michael Bartolotta, Vice Chairman, dated February 19, 2013
6. Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated March 5, 2013
7. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated February 19, 2013
8. McCarthy, Thomas: E-mail dated December 27, 2012
9. National Association of Bond Lawyers: Letter from Scott R. Lilienthal, President, dated February 22, 2013
10. National Federation of Municipal Analysts: Letter from William Oliver, Industry & Media Liaison, dated March 6, 2013
11. Sanderlin Securities: Letter from Dan Mayfield
12. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated February 19, 2013
13. Sutherland Asbill & Brennan LLP: Letter from Michael Koffler dated February 19, 2013
14. Vanguard: Letter from John C. Heywood, Principal, Retail Investor Group, dated February 19, 2013
15. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated February 19, 2013
16. Wells Fargo Securities: Letter from Gerald K. Mayfield, Senior Counsel, dated February 19, 2013
Bank Dealers, Dealers
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated February 8, 2013
2. Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated February 13, 2013
3. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated February 8, 2013
4. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated February 8, 2013
5. National Federation of Municipal Analysts: Letter from William Oliver, Industry and Media Liaison, dated February 4, 2013
6. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated February 8, 2013
Bank Dealers, Dealers
Bank Dealers, Dealers
1. Coalition of Mutual Fund Investors: Letter from Niels Holch, Executive Director, dated December 21, 2012
2. College Savings Foundation: Letter from Roger Michaud, Chairman, dated December 21, 2012
3. College Savings Plans Network: Letter from Hon. Michael L. Fitzgerald, Treasurer of Iowa and Chairman, College Savings Plans Network, dated December 21, 2012
4. College Savings Plans of Maryland: Letter from Joan Marshall, Executive Director, dated December 20, 2012
5. Financial Research Corporation: Letter from Paul Curley, Director of College Savings Research, dated December 17, 2012
6. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated December 20, 2012
7. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated December 21, 2012
8. Utah Educational Savings Plan: Letter from Lynne N. Ward, Executive Director, dated December 19, 2012
Bank Dealers, Dealers
1. Municipal Electric Authority of Georgia: Letter from James E. Fuller, Senior Vice President and Chief Financial Officer, dated December 21, 2012
2. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated December 21, 2012
Bank Dealers, Dealers
Bank Dealers, Dealers
Bank Dealers, Dealers, Municipal Advisors
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 2, 2012
2. Dorsey & Company, Inc.: Letter from Steven Rueb, Vice President, dated November 14, 2012
3. Edward D. Jones & Co., L.P.: Letter from David Fischer-Lodike, Capital Markets & Operations Compliance, dated November 2, 2012
4. Financial Planning Association: Letter from David A. Cohen, Assistant Director - Government Relations, dated November 2, 2012
5. Government Finance Officers Association: Letter from Susan Gaffney, Director, Federal Liaison Center, dated November 5, 2012
6. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated November 2, 2012
7. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated November 2, 2012
8. Rhode Island Health and Educational Building Corporation: Letter from Robert E. Donovan, Executive Director, dated October 15, 2012
9. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated November 2, 2012
10. Vanguard: Letter from Christopher Alwine, Head of Municipal Bond Group, dated November 2, 2012
Bank Dealers, Dealers
Bank Dealers, Dealers
Bank Dealers, Dealers
1. Barclays: Letter from Robert Taylor, Managing Director, Head of Municipal Finance, dated September 17, 2012
2. California Association of County Treasurers and Tax Collectors: Letter from Wayne Hammar, President, dated September 13, 2012
3. Center for Competitive Politics: Letter from Allen Dickerson, Legal Director, dated September 17, 2012
4. Government Financial Strategies Inc.: Letter from Robert W. Doty, General Counsel, dated September 17, 2012
5. Magis Advisors: Letter from Timothy J. Schaefer, President/Principal Owner, dated September 14, 2012
6. Morgan Stanley: Letter from Stratford Shields, Managing Director, dated September 17, 2012
7. National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated September 17, 2012
8. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 17, 2012
Bank Dealers, Dealers
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated September 21, 2012
2. Charles Schwab & Co. Inc.: Letter from Bari Havlik, Senior Vice President and Chief Compliance Officer, dated September 21, 2012
3. Cooley, Bruce: Letter
4. Fidelity Investments: Letter from David A. Forman, Vice President and General Counsel, dated September 21, 2012
5. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated September 21, 2012
6. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated September 21, 2012
7. TD Ameritrade, Inc.: Letter from John S. Markle, Deputy General Counsel, dated September 26, 2012
8. Wells Fargo Advisors: Letter from Ronald C. Long, Director of Regulatory Affairs, dated September 21, 2012
