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Regulatory Document Type

Compliance Resource
Publication date:
Steps for Registering as a Municipal Advisor
Information for:

Dealers, Municipal Advisors

Rule Number:

Rule G-2, Rule G-3, Rule A-12

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Notice 2025-07 - Informational Notice
Publication date:
MSRB Seeks Volunteers for Compliance Advisory Group
Information for:

Bank Dealers, Dealers, Investors, Issuers, Municipal Advisors

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Notice 2025-06 - Informational Notice
Publication date:
Issuer and Investor Notification: Posting and Accessing Preliminary Official Statements on EMMA
Information for:

Dealers, General Public, Investors, Issuers, Municipal Advisors

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Interpretive Guidance -
Publication date:
Time of Trade Disclosures in Inter-Dealer Transactions
Rule Number:

Rule G-47

For inter-dealer transactions, there is no specific requirement for brokers, dealers or municipal securities dealers (individually and collectively, “dealers”) to disclose all material facts to another dealer at time of trade. A selling dealer is not generally charged with the responsibility to ensure that the purchasing dealer knows all relevant features of the municipal securities being offered for sale. The selling dealer may rely, at least to a reasonable extent, on the fact that the purchasing dealer is also a professional and will satisfy their need for information prior to entering into a contract for the municipal securities.
 
The items of information that professionals in an inter-dealer transaction must exchange at or prior to the time of trade are governed by principles of contract law and essentially are those items necessary adequately to describe the municipal security that is the subject of the contract. As a general matter, these items of information do not encompass all material facts, but should be sufficient to distinguish the municipal security from other similar issues. The Board has interpreted Rule G-17 to require dealers to treat other dealers fairly and to hold them to the prevailing ethical standards of the industry. The rule also prohibits dealers from knowingly misdescribing municipal securities to another dealer. As a result, it is possible that non-disclosure of an unusual feature might constitute an unfair practice and thus become a violation of Rule G-17 even in an inter-dealer transaction.
 
For example, with respect to bonds that prepay principal, non-disclosure of the fact that a bond prepays principal could be a violation of Rule G-17. This would be especially true if the information about the prepayment feature is not accessible to the market and is intentionally withheld by the selling dealer. Whether or not non-disclosure constitutes an unfair practice in a specific case would depend upon the individual facts of the case. However, to avoid trade disputes and settlement delays in inter-dealer transactions, it generally is in dealers’ interest to reach specific agreement on the existence of any prepayment feature and the amount of unpaid principal that will be delivered.

 
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Notice 2025-02 - Request for Comment
Publication date: | Comment due:
Concept Release: MSRB Requests Comment on a Municipal Securities Pre-Trade Data Initiative [Withdrawn]
Information for:

Bank Dealers, Dealers, General Public, Investors

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No Comments Received
Notice 2025-01 - Informational Notice
Publication date:
Notice Concerning Trades Effected on January 9, 2025 – National Day of Mourning for Former President James Earl Carter, Jr.
Information for:

Dealers, General Public, Investors

Rule Number:

Rule G-14

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Notice 2012-64 - Informational Notice
Publication date:
SEC Approves Amendments to Streamline New Issue Information Submission Requirements Under MSRB Rules G-32 and G-34
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-8, Rule G-14, Rule G-32, Rule G-34

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Notice 2012-63 - Request for Comment
Publication date: | Comment due:
Request for Comment on MSRB Rules and Interpretive Guidance
Information for:

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

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Notice 2012-62 - Informational Notice
Publication date:
Reminder of Effective Date of New Rule and Interpretive Notice Concerning Regulation of Broker's Brokers
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-8, Rule G-9, Rule G-18, Rule G-43

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Notice 2012-61 - Request for Comment
Publication date: | Comment due:
Request for Comment on Concept Proposal to Require Underwriters to Submit Preliminary Official Statements to the MSRB’S Electronic Municipal Market Access (EMMA®) System
Information for:

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

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Notice 2012-60 - Informational Notice
Publication date:
MSRB Extends Implementation Date of Inter-Dealer Regulatory Dollar Price Reporting Requirement
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-14

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Notice 2012-59 - Request for Comment
Publication date: | Comment due:
Second Request for Comment on Draft Rule Requiring Underwriters to Submit 529 College Savings Plan Information to the MSRB
Information for:

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

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Notice 2012-58 - Request for Comment
Publication date: | Comment due:
Request for Comment on Exception Provisions of Draft Rule Amendment to Limit Dealer Consents to Changes in Authorizing Documents for Municipal Securities
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-11

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

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Notice 2012-57 - Informational Notice
Publication date:
MSRB Revises Series 53 Study Outline
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-3

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Notice 2012-53 - Informational Notice
Publication date:
SEC Approves Enhancement to Large Trade Price Transparency
Information for:

Bank Dealers, Dealers

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Notice 2012-54 - Informational Notice
Publication date:
Reminder of November 1, 2012 Effective Date Regarding Amendments to MSRB Rule G-34 Relating to Use of the Term “Not Reoffered” for New Issues of Municipal Securities
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-34

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Notice 2012-52 - Informational Notice
Publication date:
MSRB Files Amendments with SEC to Streamline New Issue Information Submission Requirements Under MSRB Rules G-32 and G-34
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-8, Rule G-14, Rule G-32, Rule G-34

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Notice 2012-51 - Informational Notice
Publication date:
Reminder of Upcoming Changes to MSRB Transaction Reporting Requirements
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-14

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Notice 2012-50 - Request for Comment
Publication date: | Comment due:
Request for Comment on Revised Draft Rule Amendments and a Revised Draft Interpretive Notice on Retail Order Periods
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-8, Rule G-11, Rule G-17, Rule G-30, Rule G-32


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

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Compliance Resource
Publication date:
New Online Procedure for Documenting Dealer System Outages
Information for:

Dealers

Rule Number:

Rule G-14

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Notice 2012-49 - Informational Notice
Publication date:
New Online Procedure for Documenting Dealer System Outages
Information for:

Bank Dealers, Dealers

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Notice 2012-48 - Informational Notice
Publication date:
Amendments to MSRB Rule G-34 Relating to Use of the Term “Not Reoffered” for New Issues of Municipal Securities Approved
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-34

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Notice 2012-47 - Informational Notice
Publication date:
MSRB Creates New Online Training Videos on Making Primary Market and Continuing Disclosure Submissions to the EMMA Website
Information for:

Bank Dealers, Dealers

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