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Notice Concerning Changes to the Comparison Eligibility of Certain Inter-dealer Transactions: Rules G-12(f) and G-14


MSRB Rule G-12(f), on automated comparison of inter-dealer transactions, requires dealers to submit all transactions eligible for automated comparison to National Securities Clearing Corporation (NSCC) for comparison. Additionally, all inter-dealer transactions eligible for trade comparison must be reported to the MSRB’s Real-Time Transaction Reporting System (RTRS) under MSRB Rule G-14[1].

On January 26, 2007, enhancements to NSCC’s comparison system for municipal securities will expand the definition of inter-dealer transactions eligible for comparison[2], and thus will expand the definition of inter-dealer transactions that must submitted for comparison under Rule G-12(f) and be reported to RTRS under Rule G-14. The MSRB believes that these enhancements will affect a small number of transactions, and should not greatly affect trade reporting.

Accrued Interest Expansion

Transactions with accrued interest up to $9,999,999.99 will be eligible for comparison. Currently, transactions with accrued interest up to $999,999.99 are eligible for comparison.

Quantities not Divisible by 1,000

Transactions in whole dollar amounts less than $1,000 will be accepted by the RTTM system. Additionally, transactions over $1,000 that are not divisible by 1,000 will be compared by submitting two transactions. For example, a transaction of 10,500 will be submitted as one transaction of 10,000 and one transaction of 500. A submission of 10,500 will continue to be rejected[3].

Questions about this notice may be directed to Sara Pranio, Uniform Practice Assistant, or to Justin Pica, Uniform Practice Policy Advisor.

[1] Under Rule G-14 Procedures, the inter-dealer trade record used for comparison, with certain additional information required for transparency and surveillance purposes, also is used to satisfy trade reporting requirements.

[2] See “RTTM Corporate, Municipal, UIT (CMU) Specification Changes for Accrued Interest & Municipal Baby Bonds,” NSCC Important Notice dated November 2, 2006, on

[3] The questionable error code, Q331 – “Par Value Not a Multiple of 1000”, will continue to be returned. As with all questionable error codes, if the transaction is correctly reported, no dealer action is required.