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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 2017-25 - Approval Notice
Publication date:
MSRB to Amend Rule G-34, on CUSIP Numbers, New Issue, and Market Information Requirements
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-34

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Notice 2017-24 - Approval Notice
Publication date:
SEC Approves Amendments to MSRB Form G-45 to Collect Additional Fee Data About ABLE Programs and 529 College Savings Plans
Information for:

Bank Dealers, Dealers, Municipal Fund Securities

Rule Number:

Rule G-45

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Notice 2017-23 - Informational Notice
Publication date:
MSRB Extends Comment Deadline on Request for Comment on Providing Compliance Support
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2017-22 - Request for Comment
Publication date: | Comment due:
MSRB Seeks Input on Compliance Support [Comment deadline extended]
Information for:

Bank Dealers, Dealers, Municipal Advisors

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated February 9, 2018

2. Breena LLC: Email from G. Letti dated November 16, 2017

3. Caine Mitter & Associates Incorporated: Email from Thomas Caine dated February 5, 2018

4. College Savings Foundation: Letter from Richard J. Polimeni, Chairman, dated February 9, 2018

5. Darren Ward: Email dated December 8, 2017

6. Financial Services Institute: Letter from Robin Traxler, Vice President, Regulatory Affairs and Associate General Counsel, dated February 9, 2018

7. Government Finance Officers Association: Letter from Emily Swenson Brock, Director, Federal Liaison Center, dated February 13, 2018

8. Investment Company Institute: Letter from Tamara K. Salmon, Associate General Counsel, dated December 21, 2017

9. National Association of Bond Lawyers: Letter from Alexandra M. MacLennan, President, dated February 23, 2018

10. National Association of Health and Educational Facilities Finance Authorities: Letter from Charles A. Samuels, Counsel for NAHEFFA, dated January 29, 2018

11. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated February 9, 2018

12. National Association of State Treasurers and College Savings Plans Network: Letter from Elizabeth Pearce, NAST President and Vermont State Treasurer, and James DiUlio, CSPN Chair and Executive Director, Wisconsin 529 College Savings Program, dated February 9, 2018

13. PFM: Letter from Leo Karwejna, Managing Director and Chief Compliance Officer, dated February 12, 2018

14. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated January 23, 2018

15. Wells Fargo Advisors: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated February 9, 2018

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Notice 2017-21 - Informational Notice
Publication date:
MSRB to Streamline Series 52 Exam Ahead of Release of FINRA Securities Industry Essentials Exam
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-3

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Compliance Resource
Publication date:
FAQs on Continuing Education Program Requirements for Municipal Advisors
Information for:

Municipal Advisors

Rule Number:

Rule G-3

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Interpretive Guidance - Interpretive Notices
Publication date:
Notice Regarding Electronic Delivery and Receipt of Information by Municipal Advisors
Rule Number:

Rule G-32

 

In November 1998, the MSRB published an interpretation about the use of electronic media to deliver and receive information by brokers, dealers and municipal securities dealers under Board rules (the “1998 interpretation”).  Since that time, the MSRB has been granted rulemaking authority over municipal advisors, and in the exercise of that authority, the MSRB has been developing a comprehensive regulatory framework for municipal advisors.

 

The Board believes that the use of electronic media to deliver and receive information under Board rules also is important for municipal advisors, and extends the guidance provided in the 1998 interpretation, as relevant, to municipal advisors.  See Rule G-32 Interpretation – Notice Regarding Electronic Delivery and Receipt of Information by Brokers, Dealers and Municipal Securities Dealers (November 20, 1998).

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Compliance Resource
Publication date:
Developing a CE Needs Analysis and Written Training Plan
Information for:

Municipal Advisors

Rule Number:

Rule G-3

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Notice 2017-20 - Informational Notice
Publication date:
MSRB Amends Professional Fee for Municipal Advisors
Information for:

Municipal Advisors

Rule Number:

Rule A-11

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Notice 2017-19 - Request for Comment
Publication date: | Comment due:
Request for Comment on a Concept Proposal Regarding Amendments to Primary Offering Practices of Brokers, Dealers and Municipal Securities Dealers
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-11, Rule G-32

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated November 16, 2017

2. City of San Diego: Letter

3. Global Legal Entity Identifier Foundation: Email from Stephan Wolf dated November 6, 2017

4. Government Finance Officers Association: Letter from Emily Brock, Director, Federal Liaison Center, dated November 27, 2017

5. Michael Paganini: Email dated September 15, 2017

6. National Association of Bond Lawyers: Letter from Alexandra M. MacLennan, President, dated November 17, 2017

7. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated November 13, 2017

8. National Federation of Municipal Analysts: Letter from Julie Egan, Chair, and Lisa Washburn, Industry Practices and Procedures Chair, dated November 9, 2017

9. Robert W. Doty: Letter dated November 2, 2017

10. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated November 15, 2017

11. TMC Bonds: Letter from John S. Craft, Managing Director, dated November 13, 2017

12. Wells Capital Management Incorporated: Letter from Gilbert L. Southwell III, Vice President, dated November 1, 2017

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Notice 2017-18 - Market Advisory
Publication date:
Notice Removed

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Compliance Resource
Publication date:
FAQs on MSRB Rules on Investor and Municipal Advisory Client Education and Protection
Information for:

Bank Dealers, Dealers, General Public, Investors, Issuers, Municipal Advisors

Rule Number:

Rule G-8, Rule G-9, Rule G-10

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Notice 2017-17 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments to MSRB Form G-45 under Rule G-45, on Reporting of Information on Municipal Fund Securities
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-45

1.  American Funds Distributors, Inc.: Letter from Maria Manotok, Senior Counsel, dated September 21, 2017

2.  Ascensus College Savings: Letter from Sandra Madden, General Counsel, dated September 21, 2017

3.  College Savings Plans Network and College Savings Foundation: Letter from Richard J. Polimeni, Chairman, College Savings Foundation, and Young Boozer, Chairman, College Savings Plans Network, dated September 21, 2017

4.  Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated September 21, 2017

5.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Bernard Canepa, Vice President and Assistant General Counsel, dated September 21, 2017

6.  State of West Virginia: Letter from John D. Perdue, State Treasurer, dated September 18, 2017

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Notice 2017-16 - Approval Notice
Publication date:
SEC Approves Amendments to the MSRB’s Rule on Municipal Fund Security Product Advertisements
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-21

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Notice 2017-15 - Approval Notice
Publication date:
SEC Approves Amendments to MSRB Rule G-26 on Customer Account Transfers
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-26

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Notice 2017-14 - Market Advisory
Publication date:
Notice Removed

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