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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 2018-31 - Approval Notice
Publication date:
SEC Approves Amendments to MSRB Form G-45 to Modify and Clarify Certain Data Elements Submitted about 529 Savings Plans and ABLE Programs
Information for:

Bank Dealers, Dealers, Municipal Fund Securities

Rule Number:

Rule G-45

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Notice 2018-29 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments to 2012 Interpretive Notice Concerning the Application of MSRB Rule G-17 to Underwriters of Municipal Securities
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-17

All Comments to Notice 2018-29

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated January 15, 2019

2. City of San Diego: Letter 

3. Government Finance Officers Association: Letter from Emily S. Brock, Director, Federal Liaison Center, dated January 15, 2019

4. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 15, 2019

5. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Bernard V. Canepa, Vice President and Assistant General Counsel, dated January 15, 2019

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Notice 2018-28 - Regulatory Reminder
Publication date:
Reminder of Requirement to Submit Word-Searchable PDF Documents to the Electronic Municipal Market Access (EMMA®) Website
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2018-27 - Informational Notice
Publication date:
MSRB Facilitates Requests for Interpretive Guidance
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2018-23 - Informational Notice
Publication date:
MSRB Expands Advisory Groups and Seeks Volunteers
Information for:

Bank Dealers, Dealers, Municipal Advisors

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Notice 2018-22 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Interpretive Guidance on Pennying and Draft Amendments to Existing Guidance on Best Execution
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-17, Rule G-18

All Comments to Notice 2018-22

1. Amuni Financial, Inc.: Letter from Mike Petagna, President, dated October 31, 2018

2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 13, 2018

3. Emmet & Co.: Email from Robert Ventrice dated September 14, 2018

4. Hartfield, Titus & Donnelly, LLC: Letter from Edward J. Smith, Chief Compliance Officer, and Christopher C. Ferreri, Chief Operating Officer, dated November 13, 2018

5. Headlands Tech Global Markets, LLC: Letter from Matthew F. Andresen, Chief Executive Officer, dated October 26, 2018

6. Regional Brokers, Inc.: Letter from Joseph A. Hemphill, III, Chief Executive Officer, and H. Deane Armstrong, Chief Compliance Officer, dated November 6, 2018

7. RW Smith & Associates, LLC: Letter from Denien Rasmussen, Co-Chief Compliance Officer, Chief Operating Officer, dated November 13, 2018

8. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated November 13, 2018

9. TMC Bonds: Letter from Thomas S. Vales, Chief Executive Officer, dated November 14, 2018

 

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Notice 2018-21 - Request for Comment
Publication date: | Comment due:
CE Council Requests Comment on Continuing Education Program Considerations
Information for:

Bank Dealers, Dealers

1. Wells Fargo Advisors: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated November 5, 2018

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Notice 2018-20 - Request for Comment
Publication date: | Comment due:
Request for Information on the Accessibility, Methodology and Utility of Indices, Yield Curves and Other Benchmarks
Information for:

Bank Dealers, Dealers, Municipal Advisors

All Comments to Notice 2018-20

1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 27, 2018

2. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated November 28, 2018

3. Securities Industry and Financial Markets Association: Letter from Michael Decker, Managing Director, dated November 27, 2018

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Notice 2018-17 - Regulatory Reminder
Publication date:
Compliance Advisory for Brokers, Dealers and Municipal Securities Dealers
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-11, Rule G-15, Rule G-18, Rule G-19, Rule G-23, Rule G-27, Rule G-30

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Notice 2018-19 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Frequently Asked Questions Regarding Use of Social Media under MSRB Advertising Rules
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-21, Rule G-40

All Comments to Notice 2018-19

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated September 14, 2018

2. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated September 17, 2018

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

4. Wells Fargo Advisors: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated September 14, 2018

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Compliance Resource
Publication date:
Supervisory Responsibilities of Qualified Principals
Information for:

Dealers

Rule Number:

Rule G-3, Rule G-27

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Compliance Resource
Publication date:
Resource on Disclosing Mark-ups and Determining Prevailing Market Price
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-15, Rule G-30

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Notice 2018-16 - Approval Notice
Publication date:
MSRB Temporarily Reduces Underwriting, Transaction and Technology Fees Assessed on Dealers
Information for:

Bank Dealers, Dealers

Rule Number:

Rule A-13

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Notice 2018-15 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments to MSRB Rules on Primary Offering Practices
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-11, Rule G-32

All Comments to Notice 2018-15

1. Acacia Financial Group, Inc.: Letter from Noreen P. White, Co-President, and Kim M. Whelan, Co-President, dated September 17, 2018

2. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated September 17, 2018

3. C F I: Email from Stephen Holstein dated July 25, 2018

4. Ehlers Associates, Inc.: Letter from Steve Apfelbacher dated September 17, 2018

5. Government Finance Officers Association: Letter from Emily S. Brock, Director, Federal Liaison Center, dated September 19, 2018 

6. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated September 18, 2018

7. National Federation of Municipal Analysts: Letter from Julie Egan, NFMA Industry Practices and Procedures Chair, and Lisa Washburn, NFMA Industry Practices and Procedures Co-Chair, dated September 17, 2018

8. Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated September 17, 2018

9. Public Resources Advisory Group: Letter from Marianne F. Edmonds dated September 18, 2018

10. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 17, 2018

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Notice 2018-13 - Informational Notice
Publication date:
MSRB Revises Content Outlines for Professional Qualification Examinations
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-3

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Notice 2018-11 - Informational Notice
Publication date:
MSRB Modifies Professional Qualifications Program
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-3

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Notice 2018-10 - Request for Comment
Publication date: | Comment due:
Request for Comment: Retrospective Review of 2012 Interpretive Notice Concerning the Application of MSRB Rule G-17 to Underwriters of Municipal Securities
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule G-17

All Comments to Notice 2018-10

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated August 6, 2018

2. Government Finance Officers Association: Letter from Emily S. Brock, Director, Federal Liaison Center, dated August 6, 2018

3. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated August 6, 2018

4. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated August 6, 2018

5. State of Florida, Division of Bond Finance: Letter from J. Ben Watkins III, Director, dated August 8, 2018

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Notice 2018-09 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft MSRB Rule G-36, on Discretionary Transactions in Customer Accounts, and Related Draft Amendments
Information for:

Bank Dealers, Dealers

Rule Number:

Rule G-8, Rule G-36, Rule D-10

All Comments to Notice 2018-09

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated July 16, 2018

2. Financial Services Institute: Letter from Robin Traxler, Vice President, Regulatory Affairs and Associate General Counsel, dated July 16, 2018

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated July 16, 2018

 

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