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Compliance Resource
Publication date:
Information for:

Dealers, Municipal Advisors

Notice 2025-08 - Request for Comment
Publication date: | Comment due:
Notice 2025-07 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Investors, Issuers, Municipal Advisors

Notice 2025-06 - Informational Notice
Publication date:
Information for:

Dealers, General Public, Investors, Issuers, Municipal Advisors

Compliance Resource
Publication date:
Information for:

Municipal Advisors

Rule Number:

Rule G-2, Rule G-3

Compliance Resource
Publication date:
Information for:

Municipal Advisors

Rule Number:

Rule G-2, Rule G-3

Notice 2025-05 - Approval Notice
Publication date:
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.

 
Notice 2025-04 - Informational Notice
Publication date:
Notice 2025-03 - Informational Notice
Publication date:
Notice 2025-02 - Request for Comment
Publication date: | Comment due:
Notice 2025-01 - Informational Notice
Publication date:
Notice 2017-25 - Approval Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-34

Notice 2017-24 - Approval Notice
Publication date:
Notice 2017-23 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Notice 2017-22 - Request for Comment
Publication date: | Comment due:
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

Notice 2017-21 - Informational Notice
Publication date:
Compliance Resource
Publication date:
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).

Compliance Resource
Publication date:
Information for:

Municipal Advisors

Rule Number:

Rule G-3

Notice 2017-20 - Informational Notice
Publication date:
Information for:

Municipal Advisors

Rule Number:

Rule A-11

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