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Compliance Resource
Publication date:
Information for:

Dealers, Municipal Advisors

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

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 2025-02 - Request for Comment
Publication date: | Comment due:
Notice 2025-01 - Informational Notice
Publication date:
Notice 2020-19 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

All Comments to Notice 2020-19

1. 280 Securities LLC: Letter from Wm. Thomas Lockard, Managing Director, dated January 6, 2021

2, American Bankers Association: Letter from Justin M. Underwood dated January 11. 2021

3. American Securities Association: Kelli McMorrow, Head of Government Affairs, dated January 11, 2021

4. Belton, David F.: Letter

5. Bliss, Evan: Email dated January 13, 2021

6. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated January 11, 2021

7. Ceres, Inc.: Letter from Steven M. Rothstein, Managing Director, Ceres Accelerator for Sustainable Capital Markets, dated January 11, 2021

8. Climate Advisory: Letter from Lisa L. Churchill, Founder, dated January 11, 2021

9. Geos Institute: Email from Tonya Graham dated January 11, 2021

10. Global Legal Entity Identifier Foundation: Letter from Stephan Wolf, CEO, dated January 5, 2021

11. Government Finance Officers Association: Letter from Emily Swanson Brock, Director, Financial Liaison Center, dated January 11, 2021

12. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 11, 2021

13. National Association of State Treasurers: Letter from Shaun Snyder, Executive Director, dated January 11, 2021

14. PFM Financial Advisors LLC: Letter from Leo Karwejna, Managing Director, Chief Compliance Officer, dated January 12, 2021

15. 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 11, 2021

16. Ugarte, Allyson: Letter dated January 11, 2021

17. XBRL US: Letter from Campbell Pryde, President and CEO, dated January 11, 2021

Notice 2020-18 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Notice 2020-17 - Informational Notice
Publication date:
Notice 2020-16 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors, Municipal Fund Securities

Notice 2020-15 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-3, Rule A-4

Notice 2020-14 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-3, Rule A-6

Notice 2020-13 - Approval Notice
Publication date:
Notice 2020-12 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

IF-3

Notice 2020-11 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-13

Notice 2020-09 - Informational Notice
Publication date:
Notice 2020-08 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-3

Notice 2020-07 - Informational Notice
Publication date:
Notice 2020-06 - Informational Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Notice 2020-05 - Informational Notice
Publication date:
Notice 2020-04 - Approval Notice
Publication date:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

IF-3

Notice 2020-03 - Informational Notice
Publication date:
Compliance Resource
Publication date:
Information for:

Dealers, General Public, Investors, Issuers, Municipal Advisors

Rule Number:

Rule G-17, Rule G-42

Notice 2020-02 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

Rule Number:

Rule A-3

All Comments to Notice 2020-02

1. Acacia Financial Group, Inc.: Letter from Kim M. Whelan, Co-President, and Noreen P. White, Co-President, dated April 29, 2020

2. Action Center on Race and the Economy, AFSCME, AFL-CIO, Americans for Financial Reform Education Fund, Consumer Federation of America and Public Citizen: Letter dated April 29, 2020

3. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated April 29, 2020

4. Government Finance Officers Association: Letter from Emily Swenson Brock, Director, Federal Liaison Center, dated April 29, 2020

5. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated April 15, 2020

6. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated April 29, 2020

7. National Association of State Auditors, Comptrollers and Treasurers: Letter from Beth Pearce, President, dated April 30, 2020

8.  National Association of State Treasurers: Letter from Shaun Snyder, Executive Director, dated April 28, 2020

9. National Federation of Municipal Analysts: Letter from Nicole Byrd, Chair, dated April 29, 2020

10. 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 April 29, 2020

11. Steve Apfelbacher, Renee Boicourt, Marianne Edmonds, Robert Lamb, Nathaniel Singer and Noreen White [former MSRB Board members]: Letter dated April 29, 2020

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