The MSRB is clarifying for brokers, dealers and municipal securities dealers (collectively “dealers”) those days that are not considered business days for determining the deadlines in MSRB rules for making submissions to MSRB transparency programs. To clarify these non-business days, the MSRB has added a “holiday schedule” to the system status page on the MSRB website. The holiday schedule should assist dealers with determining the submission deadlines associated with Rule G-14, on transaction reporting, Rule G-32, on disclosures in connection with primary offerings, and Rule G-34(c), on variable rate security market information.
Trade Data and Variable Rate Security Interest Rate Information Submissions
The MSRB Real-Time Transaction Reporting System (RTRS) and Short-term Obligation Rate Transparency (SHORT) System are available for submissions of trade reports as well as current interest rates and related information for auction rate securities and variable rate demand obligations on business days during the hours of 6:00 AM to 9:00 PM Eastern. Rule G-14 specifies deadlines for reporting transactions to RTRS executed between the hours of 7:30 AM to 6:30 PM Eastern on business days and MSRB reminds dealers that trades executed outside of those hours or on non-business days must be reported by no later than 7:45 AM Eastern on the next business day. Rule G-34(c) specifies deadlines for reporting interest rate resets to the SHORT System that occur before 6:30 PM Eastern on business days and specifies that interest rate resets that occur after that time or on non-business days must be submitted by no later than 6:30 PM Eastern on the next business day.
Primary Market and Variable Rate Security Document Submissions
Dealers may submit documents to the MSRB using the Electronic Municipal Market Access (EMMA) Dataport system or SHORT System at any time on business and non-business days. The document submission requirements of Rule G-32 and Rule G-34(c) specify submission deadlines relative to the date a dealer receives a document. For these deadlines, the receipt date must reflect the actual date of receipt, even if such date is a non-business day. From the receipt date, the deadline for submitting the document to the MSRB must be determined from counting the relevant number of business days that may elapse under the rule. Therefore, a document that is required to be submitted to the MSRB no more than one business day after receipt that is received on a non-business day would be required to be submitted by the end of the next business day. For example, a document received on a Saturday that is required to be submitted to the MSRB no more than one business day after receipt would be required to be submitted by the end of the day on Monday, or the next business day in the event that Monday is a non-business day.
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Questions about this notice may be directed to Justin R. Pica, Director of Product Management - Market Transparency at 703-797-6716.
October 4, 2011
 Note that trades executed before 7:30 AM Eastern on a business day must be reported by no later than 7:45 AM Eastern the same day. In addition, MSRB has published procedures for reporting inter-dealer transactions executed on non-business days. See MSRB Notice 2007-12 (March 23, 2007).
 For variable rate demand obligations (VRDOs), the date and time that the interest rate reset occurs reflects the date and time that a VRDO Remarketing Agent determines the interest rate for the next interest rate period. This date and time may differ from the date and time that the interest rate becomes effective. See MSRB Notice 2009-17 (May 5, 2009).
 Note that MSRB reserves the period between 3:00 AM and 6:00 AM Eastern for routine maintenance and these systems may not be available for submissions of documents during those times.