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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 2025-04 - Informational Notice
Publication date:
Delayed Announcement of Effective Date for Amendment to MSRB Rule G-14 to Shorten Timeframe for Reporting Transactions in Municipal Securities
Information for:

General Public, Investors

Rule Number:

Rule G-12, Rule G-14, IF-1

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Notice 2025-03 - Informational Notice
Publication date:
Designation Information Regarding Mandatory Participation in Business Continuity and Disaster Recovery Testing
Information for:

Municipal Advisors

Rule Number:

Rule A-18

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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 2013-22 - Request for Comment
Publication date: | Comment due:
MSRB Proposes Changes to Continuing Education Program
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-3, Rule G-7, Rule G-27


1.  Bartholomew, Patricia E., 2014 Chair, Securities Industry Council on Continuing Education, and Bartol, William E., 2013 Chair, Securities Industry Council on Continuing Education: Letter dated January 13, 2014

2.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated January 13, 2014

3.  Diamant Investment Corporation: E-mail from Herbert Diamant dated December 13, 2013

4.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated January 13, 2014

5.  Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated January 13, 2014

6.  MetLife Securities, Inc.: Letter from Jennifer Lewis, Corporate Counsel, dated January 13, 2014

7.  National Society of Compliance Professionals: Letter from Judy Werner, Executive Director, dated January 14, 2014

8.  Romano Wealth Management: E-mail from Joe Romano dated January 13, 2014

9.  RW Smith & Associates, Inc.: E-mail from Paige Pierce dated January 13, 2014

10.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated January 13, 2014

11.  Wulff, Hansen & Co.: Letter from Chris Charles, President, dated January 9, 2014

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Notice 2013-21 - Informational Notice
Publication date:
MSRB to Implement Protections for Investors Against Unexpected Changes in Bond Authorizing Documents
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-11

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Notice 2013-20 - Informational Notice
Publication date:
SEC Approves Amendments to MSRB Rules G-11, G-8 and G-32 to Include Provisions Specifically Tailored for Retail Order Periods
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-8, Rule G-11, Rule G-32

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Notice 2013-19 - Request for Comment
Publication date: | Comment due:
Request for Comment on Proposed Rule Change to Consolidate Registration Requirements
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-12


1. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated September 20, 2013

2. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated September 20, 2013

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 20, 2013

4. U.S. Bancorp Investments, Inc.: E-mail from Herbert Neufeld dated August 19, 2013

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Notice 2013-18 - Informational Notice
Publication date:
MSRB Market Transparency Advisory – Suggested Practices in Submitting of Financial Disclosures to EMMA
Information for:

Bank Dealers, Dealers

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Notice 2013-17 - Informational Notice
Publication date:
Notice Regarding MSRB Policy on Interpretive Guidance
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2013-15 - Request for Comment
Publication date: | Comment due:
Request for Comment on Proposed Fair-Pricing Rule
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-18, Rule G-30

1. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated September 20, 2013

2. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated September 20, 2013

3. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated September 20, 2013

4. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated September 20, 2013

5. Wells Fargo Securities: Letter from Gerald K. Mayfield, Senior Counsel, dated September 20, 2013

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Notice 2013-16 - Request for Comment
Publication date: | Comment due:
Request for Comment on Whether to Require Dealers to Adopt a "Best Execution" Standard for Municipal Securities Transactions
Information for:

Bank Dealers, Dealers


1. Ambassador Financial Group: E-mail from Allen Collins dated August 8, 2013

2. Barclays Capital Inc.: Letter from Jennifer Small, Municipal Compliance, dated October 7, 2013

3. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated October 7, 2013

4. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated October 7, 2013

5. Interactive Data Corporation: Letter from Mark Hepsworth, President, Interactive Data Pricing and Reference Data, dated October 7, 2013

6. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated September 20, 2013

7. J.J.B. Hilliard, W.L. Lyons LLC: Letter from Alex Rorke, Director, Public Finance

8. Melton, Chris: Letter dated September 26, 2013

9. Private Investor: E-mail from Private Investor dated September 2, 2013

10. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated October 7, 2013

11. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated October 7, 2013

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Notice 2013-14 - Request for Comment
Publication date: | Comment due:
Concept Release on Pre-Trade and Post-Trade Pricing Data Dissemination through a New Central Transparency Platform
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-14


1.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 1, 2013

2.  Corporate Treasury Investment Consulting LLC: Letter from Mark O. Conner, Principal, dated August 16, 2013

3.  Financial Information Forum: Letter from Manisha Kimmel, Executive Director, dated November 1, 2013

4.  Interactive Data Corporation: Letter from Mark Hepsworth, President, Interactive Data Pricing and Reference Data, dated November 1, 2013

5.  Leonard, Jack: Letter dated August 1, 2013

6.  Long, Cate: E-mail dated November 1, 2013

7.  Sayer, Steven: E-mail dated November 3, 2013

8.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated November 1, 2013

9.  Wells Fargo Advisors, LLC: Letter from Robert J.McCarthy, Director of Regulatory Policy, dated November 1, 2013

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Notice 2013-13 - Informational Notice
Publication date:
Notice Regarding Transactions in Direct-Pay Municipal Bonds Subject to Subsidy Reductions Due to the Federal Sequester
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-17, Rule G-18, Rule G-19, Rule G-30

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Notice 2013-12 - Informational Notice
Publication date:
SEC Approves Amendments to MSRB Rule G-39, on Telemarketing
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-39

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Notice 2013-11 - Informational Notice
Publication date:
Enhancements to New Issue Information on EMMA
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-32, Rule G-34

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Compliance Resource
Publication date:
Presentation on Changes to Rules Relating to New Issue Reporting
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-33

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Notice 2013-10 - Request for Comment
Publication date: | Comment due:
Request for Comment on Proposed Sophisticated Municipal Market Professional Rules
Information for:

Bank Dealers, Dealers

1.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated June 12, 2013

2.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated June 12, 2013

3.  Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated June 12, 2013

 

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Notice 2013-08 - Informational Notice
Publication date:
MSRB Answers Frequently Asked Questions (FAQs) Regarding an Underwriter’s Disclosure Obligations to State and Local Government Issuers under Rule G-17
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-17

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Notice 2013-07 - Request for Comment
Publication date: | Comment due:
Request for Comment on Revisions to Suitability Rule
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-8, Rule G-19

1.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated May 6, 2013

2.  College Savings Foundation: Letter from Roger Michaud, Chairman, dated May 6, 2013

3.  College Savings Plans Network: Letter from Michael L. Fitzgerald, Treasurer of Iowa and Chairman, dated May 6, 2013

4.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated May 6, 2013

5.  Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated May 5, 2013

6.  Retail Investor: Email from Retail Investor dated August 25, 2013

7.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated May 6, 2013

8.  Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated May 6, 2013

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Notice 2013-06 - Request for Comment
Publication date: | Comment due:
MSRB Seeks Input on Annual Planning
Information for:

Bank Dealers, Dealers, Municipal Advisors


1.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated March 28, 2013

2.  Boyle, Nick: Letter

3.  City of Milwaukee: E-mail from Richard Li dated March 7, 2013

4.  Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated April 30, 2013

5.  National Association of Bond Lawyers: Letter from Scott R. Lilienthal, President, dated March 29, 2013

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