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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 2015-23 - Informational Notice
Publication date:
MSRB Provides Implementation Guidance on MSRB Rule G-18, on Best Execution
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-18, Rule G-48, Rule D-15

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Notice 2015-22 - Request for Comment
Publication date: | Comment due:
Request for Comment on Changes to MSRB Rules to Facilitate Shortening the Securities Settlement Cycle
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-12, Rule G-15

1.  Bernardi Securities, Inc.: Letter from Eric Bederman, SVP, Chief Operating & Compliance Officer, dated November 17, 2015

2.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated December 10, 2015

3.  Brandis Tallman LLC: Letter from Richard Brandis

4.  Castle Advisory Company: E-mail from Garth Schulz dated November 10, 2015

5.  Coastal Securities: E-mail from Chris Melton, Executive Vice President, dated December 10, 2015

6.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President & General Counsel, dated December 10, 2015

7.  Geraldine Lettieri: E-mail dated November 10, 2015

8.  Investment Company Institute: Letter from Martin A. Burns, Chief Industry Operations Officer, dated December 1, 2015

9.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated December 10, 2015

 

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Notice 2015-21 - Informational Notice
Publication date:
SEC Approves Amendments to MSRB Rule G-20 on Gifts, Gratuities and Non-Cash Compensation and Related Amendments to MSRB Rule G-8
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-8, Rule G-20

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Notice 2015-20 - Informational Notice
Publication date:
MSRB Adopts Rule Requiring Participation in Business Continuity and Disaster Recovery Testing
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2015-19 - Informational Notice
Publication date:
MSRB Extends Comment Deadline on Confirmation Disclosure Proposal
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-15

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Notice 2015-18 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments to MSRB Rule A-3 to Lengthen the Term of Board Member Service
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-3

1.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 19, 2015

2.  National Association of Municipal Advisors: Letter from Terri Heaton, President, dated November 19, 2015

3.  Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated October 29, 2015

4.  Securities Industry Financial Markets Association: Letter from Michael Decker, Managing Director, dated November 19, 2015

5.  Stephen Heaney: E-mail dated November 10, 2015

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Notice 2015-17 - Informational Notice
Publication date:
MSRB Amends its Continuing Education Requirements to Facilitate Web-based Delivery of Regulatory Element Training
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-3

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Notice 2015-16 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Rule Amendments to Require Confirmation Disclosure of Mark-ups for Specified Principal Transactions with Retail Customers (Comment deadline extended)
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-15

1.  Aaron Botbyl: E-mail dated October 9, 2015

2.  Bernardi Securities, Inc.: Letter from Eric Bederman, SVP, Chief Operating & Compliance Officer, dated December 4, 2015

3.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated December 11, 2015

4.  CFA Institute: Letter from Kurt N. Schacht, Managing Director, Standards and Financial Market Integrity, and Linda L. Rittenhouse, Director, Capital Markets Policy, dated December 11, 2015

5.  Charles Schwab & Co. Inc.: Letter from Jason Clague, Senior Vice President, Trading & Middle Office Services, dated December 11, 2015

6.  Chris Melton: E-mail dated October 30, 2015

7.  Christopher [last name withheld]: E-mail dated September 25, 2015

8.  Consumer Federation of America: Letter from Micah Hauptman, Financial Services Counsel, dated December 11, 2015

9.  Diamant Investment Corporation: Letter from Herbert Diamant, President, dated November 30, 2015

10.  Fidelity Investments: Letter from Norman L. Ashkenas, Chief Compliance Officer, Fidelity Brokerage Services, LLC, and Richard J. O'Brien, Chief Compliance Officer, National Financial Services, LLC, dated December 11, 2015

11.  Financial Information Forum: Letter from Darren Wasney, Program Manager, dated December 11, 2015

12.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President & General Counsel, dated December 11, 2015

13.  Gerald Heilpern: Letter 

14.  Jonathan Bricker: E-mail dated October 20, 2015

15.  LPL Financial LLC: Letter from David P. Bergers, General Counsel, dated December 10, 2015

16.  Morgan Stanley Smith Barney LLC: Letter from Elizabeth Dennis, Managing Director, dated December 11, 2015

17.  Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated December 11, 2015

18.  Patrick Luby: Letter dated December 11, 2015

19.  Public Investors Arbitration Bar Association: Letter from Hugh D. Berkson, President, dated December 8, 2015

20.  RBC Capital Markets, LLC: Letter from David L. Cohen, Senior Counsel and Director, dated December 15, 2015

21.  RW Smith & Associates, LLC: Letter from Paige W. Pierce, President & CEO, dated December 11, 2015

22.  Securities Industry and Financial Markets Association: Letter from Sean Davy, Managing Director, Capital Markets Division, and Leslie M. Norwood, Managing Director & Associate General Counsel, Municipal Securities Division, dated December 11, 2015

23.  Thomson Reuters: Letter from Manisha Kimmel, Chief Regulatory Officer, Wealth Management, dated December 11, 2015

24.  TMC Bonds, LLC: Letter from Thomas S. Vales, Chief Executive Officer, dated December 11, 2015

25.  Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated December 11, 2015

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Notice 2015-14 - Informational Notice
Publication date:
MSRB Revises Effective Date for MSRB Rule G-18, on Best Execution of Transactions in Municipal Securities, and Related Rule Amendments
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-18, Rule G-48, Rule D-15

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Notice 2015-13 - Informational Notice
Publication date:
MSRB Adjusts Fees to Align Revenues with Operational and Capital Expenses
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-12, Rule A-13

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Notice 2015-12 - Informational Notice
Publication date:
MSRB Revises Content Outlines for its Professional Qualification Examinations for Municipal Securities Dealers
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-3

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Notice 2015-11 - Informational Notice
Publication date:
MSRB Documents System Hours in EMMA System, RTRS and SHORT System Information Facilities
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2015-10 - Request for Comment
Publication date: | Comment due:
Request for Comment on Establishment of an Academic Historical Trade Data Product
Information for:

Bank Dealers, Dealers, Municipal Advisors

1.  American Governmental Financial Services: E-mail from Robert Doty dated August 24, 2015

2,  Andrew Glassberg: E-mail dated August 17, 2015

3.  Association for Budgeting and Financial Management: Letter from Robert Kravchuk, Chair, et al., dated September 13, 2015

4.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated August 24, 2015

5.  Brandeis University: Letter from Daniel Bergstresser, Associate Professor of Finance, dated September 14, 2015

6.  Coastal Securities: E-mail from Chris Melton, Executive Vice President, dated August 5, 2015

7.  George Mason University: Letter from Jonathan L. Gifford, Professor and Director of Center for Transportation P3 Policy, dated September 1, 2015

8.  John Mousseau: E-mail dated July 29, 2015

9.  Larry Harris: Letter dated September 6, 2015

10.  New York University: Letter from Norman White, Clinical Professor, et al., dated September 16, 2015

11.  Pennsylvania State University: Letter from Patrick J. Cusatis, Associate Professor of Finance, dated September 10, 2015

12.  Securities Industry and Financial Markets Association: Letter from Sean Davy, Managing Director, Capital Markets Division, and David L. Cohen, Managing Director and Associate General Counsel, Municipal Securities Division, dated September 11, 2015

13.  University of Louisville: Letter from James R. Ramsey, President, dated September 4, 2015

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Notice 2015-09 - Informational Notice
Publication date:
MSRB to Extend Due Date for First Submissions Under MSRB Rule G-45, Reporting of Information on Municipal Fund Securities
Information for:

Bank Dealers, Dealers, Municipal Fund Securities

Rule Number:

Rule G-45

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Notice 2015-08 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments and Other Issues Related to MSRB Rule A-3 on Membership on the Board
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-3

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

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Notice 2015-07 - Informational Notice
Publication date:
SEC Approves Amendments to MSRB Rule G-14 and Real-Time Transaction Reporting System
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-14

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Notice 2015-05 - Informational Notice
Publication date:
MSRB Amends Fees Charged for Qualification Examinations
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-16

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Notice 2015-04 - Informational Notice
Publication date:
MSRB to Amend Rules to Create Professional Qualification Standards for Municipal Advisors
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-1, Rule G-2, Rule G-3, Rule D-13

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