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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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Compliance Resource
Publication date:
MSRB Form G-32
Information for:

Dealers, Investors

Rule Number:

Rule G-32

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Notice 2016-29 - Informational Notice
Publication date:
Interpretive Notice on the Application of MSRB Rules to Transactions in Managed Accounts
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-48, Rule D-15

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Notice 2016-28 - Approval Notice
Publication date:
New Disclosure Requirements Under MSRB Rule G-15 and Prevailing Market Price Guidance Pursuant to Rule G-30 Effective May 14, 2018
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-15, Rule G-30

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Notice 2016-27 - Informational Notice
Publication date:
Interpretive Notice Regarding Rule G-47, on Time of Trade Disclosure
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-47

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Notice 2016-26 - Informational Notice
Publication date:
MSRB Announces the Effective Date of the Academic Historical Transaction Data Product
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2016-23 - Request for Comment
Publication date: | Comment due:
Second Request for Comment on Draft Provisions on Minimum Denominations
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-15

1.  Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated October 18, 2016

2.  Darcy Versions I and II: E-mail from G. Letti dated September 27, 2016

3.  Financial Services Institute: Letter from David T. Bellaire, Executive Vice President & General Counsel, dated October 11, 2016

4.  James J. Angel: Letter dated October 22, 2016

5.  National Association of Bond Lawyers: Letter from Clifford M. Gerber, President, dated December 23, 2016

6.  Romano Brothers & Co.: Letter from Eric Bederman, Chief Operating and Compliance Officer, dated October 18, 2016

7.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated October 18, 2016

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Notice 2016-22 - Approval Notice
Publication date:
SEC Approves MSRB Academic Historical Transaction Data Product
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2016-21 - Approval Notice
Publication date:
SEC Approves Amendments to MSRB Rule G-12 on Close-Out Procedures
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-12

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Notice 2016-19 - Informational Notice
Publication date:
MSRB Provides Guidance on MSRB Rule G-14, on Reports of Sales or Purchases of Municipal Securities
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-14

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Compliance Resource
Publication date:
MSRB Provides Guidance on MSRB Rule G-14, on Reports of Sales or Purchases of Municipal Securities
Information for:

Dealers

Rule Number:

Rule G-14

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Notice 2016-18 - Informational Notice
Publication date:
MSRB Files Amendment to Rule G-37 to Clarify its Application to Contributions before August 17, 2016
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-37

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Compliance Resource
Publication date:
MSRB Files Amendment to Rule G-37 to Clarify its Application to Contributions before August 17, 2016
Information for:

Dealers, Issuers, Municipal Advisors

Rule Number:

Rule G-8, Rule G-9, Rule G-37

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Notice 2016-15 - Informational Notice
Publication date:
MSRB to Amend Rules to Define Two-Day Settlement Cycle
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-12, Rule G-15

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Notice 2016-14 - Informational Notice
Publication date:
Municipal Fund Securities - Interpretation Relating to the Sales of Interests in ABLE Programs in the Primary Market
Information for:

Bank Dealers, Dealers, Municipal Advisors, Municipal Fund Securities

Rule Number:

Rule D-12

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Notice 2016-13 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments to MSRB Rule G-15(f) on Minimum Denominations
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-15

1.  American Municipal Securities, Inc.: Letter from Michael Petagna, President, dated May 25, 2016

2.  Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated May 25, 2016

3.  Breena LLC: E-mail from G. Letti dated April 19, 2016

4.  Center for Municipal Finance: Letter from Marc D. Joffe, President, dated April 7, 2016

5.  Neighborly.com: E-mail from Jase Wilson dated May 25, 2016

6.  Regional Brokers, Inc.: Letter from H. Deane Armstrong, CCO

7.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated May 25, 2016

8.  Thomas Kiernan: E-mail dated April 7, 2016

9.  Vista Securities: E-mail from Rick DeLong dated May 9, 2016

10.  Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated May 25, 2016

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Notice 2016-12 - Informational Notice
Publication date:
Direct Purchases and Bank Loans as Alternatives to Public Financing in the Municipal Securities Market
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2016-11 - Request for Comment
Publication date: | Comment due:
Request for Comment on a Concept Proposal to Improve Disclosure of Direct Purchases and Bank Loans
Information for:

Bank Dealers, Dealers, Municipal Advisors

1.  American Bankers Association: Letter from Cristeena G. Naser, Vice President, Center for Securities, Trust and Investments, dated May 27, 2016

2.  American Governmental Financial Services Company: E-mail from Robert Doty dated May 31, 2016

3.  Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated May 27, 2016

4.  Breena LLC: E-mail from G. Letti dated March 28, 2016; and e-mail from G. Letti dated May 1, 2016

5.  Caine Mitter & Associates Incorporated: E-mail from Thomas Caine dated May 27, 2016

6.  Cavanal Hill Investment Management: E-mail from Douglas Benton dated May 2, 2016

7.  Charles Schwab Investment Management: Letter from Marie Chandoha, President and Chief Executive Officer, dated May 27, 2016

8.  Dixworks LLC: E-mail from Dennis Dix, Jr. dated March 29, 2016

9.  George K. Baum & Company: Letter from Guy E. Yandel, Executive Vice President; Dana L. Bjornson, Executive Vice President and Chief Compliance Officer; and Andrew F. Sears, Executive Vice President and General Counsel; dated May 26, 2016

10.  Government Finance Officers Association: Letter from Emily Brock, Director, Federal Liaison Center, dated May 27, 2016

11.  Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated May 27, 2016

12.  Kane, McKenna Capital, Inc.: Letter from Philip R. McKenna, President, dated April 7, 2016

13.  Lawrence Financial Consulting LLC: E-mail from Tom Lawrence dated March 30, 2016; and letter from Tom Lawrence, President, dated May 2, 2016

14.  Lewis Young Robertson & Burningham: Letter from Laura D. Lewis, Principal, dated May 26, 2016

15.  National Association of Bond Lawyers: Letter from Kenneth R. Artin, President, dated May 27, 2016

16.  National Association of Health and Educational Facilities Finance Authorities: Letter from Donna Murr, President; Martin Walke, Advocacy Committee Chairman; and Charles Samuels, General Counsel; dated May 26, 2016

17.  National Association of Municipal Advisors: Letter from Terri Heaton, President, dated May 26, 2016

18.  National Association of State Treasurers: Letter

19.  National Federation of Municipal Analysts: Letter from Lisa Washburn, Chair, dated May 23, 2016

20.  Public Financial Management, Inc,: Letter from Leo Karwejna, Chief Compliance Officer, and Cheryl Maddox, General Counsel, dated May 26, 2016

21.  Public Resources Advisory Group: Letter from Marianne F. Edmonds, Senior Managing Director, dated May 27, 2016

22.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated May 26, 2016

23.  Securities Industry and Financial Markets Association, Asset Management Group: Letter from Timothy W. Cameron, Asset Management Group - Head, and Lindsey W. Keljo, Vice President and Assistant General Counsel, Asset Management Group, dated May 27, 2016

24.  State of Florida, Division of Bond Finance: Letter from J. Ben Watkins III, Director, dated May 27, 2016

25.  Sycamore Advisors, LLC: E-mail from Courtney Tobin dated June 8, 2016

26.  Thomson Reuters: Letter from Michael C. Demas, Head, Municipal Evaluations, dated May 27, 2016

27.  Wake County, North Carolina: Letter from Nicole Kreiser, Debt Manager, dated May 26, 2016

28.  WM Financial Strategies: Letter from Joy A. Howard, Principal, dated May 27, 2016

29.  Wulff, Hansen & Co.: Letter from Chris Charles, President

30.  Zions Bank: Letter from James G. Livingston, Senior Vice President, dated May 25, 2016

   

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