Rule G-34, on CUSIP Numbers and New Issue Requirements

Recent amendments to MSRB Rule G-34 extended to all municipal advisors, when advising on competitive transactions in municipal securities, a requirement to apply for CUSIP numbers within specified time frames. In the brief time since this requirement went into effect, numerous municipal advisors and their representatives have expressed to the MSRB questions regarding the need for this requirement and concerns about the burdens associated with it, based upon their experience with the requirement since it became effective.

The MSRB believes that it is appropriate to solicit comments and to obtain any available data from all stakeholders concerning, among other things, whether the requirement addresses actual market harms; is appropriate to the role of the municipal advisor in some or all instances; imposes undue burdens on municipal advisors; and raises any considerations relating to competition among regulated entities.

Read Rule G-34 and its interpretive guidance.