Select regulatory documents by category:
Bank Dealers, Dealers, General Public, Investors
- Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated December 15, 2023
Dealers
Bank Dealers, Dealers, Municipal Advisors
Bank Dealers, Dealers
Bank Dealers, Dealers
Bank Dealers, Dealers
1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated March 4, 2016
2. Breena LLC: E-mail from Geraldine Lettieri dated January 6, 2016
3. National Securities Clearing Corporation: Letter from Murray C. Pozmanter, Managing Director, dated January 12, 2016
4. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 6, 2016
1. Bernardi Securities, Inc.: Letter from Eric Bederman, SVP, Chief Operating & Compliance Officer, dated November 17, 2015
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated December 10, 2015
3. Brandis Tallman LLC: Letter from Richard Brandis
4. Castle Advisory Company: E-mail from Garth Schulz dated November 10, 2015
5. Coastal Securities: E-mail from Chris Melton, Executive Vice President, dated December 10, 2015
6. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President & General Counsel, dated December 10, 2015
7. Geraldine Lettieri: E-mail dated November 10, 2015
8. Investment Company Institute: Letter from Martin A. Burns, Chief Industry Operations Officer, dated December 1, 2015
9. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated December 10, 2015
Comments on MSRB Notice 2009-20 (May 12, 2009)
- First Southwest Company: Letter from Hill A. Feinberg, Chairman, dated June 26, 2009
- Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated June 29, 2009
Automated Comparison and Transaction Reporting of Certain Inter-Dealer Transactions in When-Issued Municipal Securities: Rules G-12(f) and G-14
The MSRB has received reports of problems with automated comparison and transaction reporting of certain inter-dealer transactions involving syndicate managers. These reports indicate that some dealers may have incorrectly identified some of their when, as and if issued ("when-issued") transactions in new issue municipal securities as "syndicate transactions." The MSRB reminds dealers that erroneous coding of comparison reports is a violation of Rule G-14, on transaction reporting, and that transactions with dealers that are not members of the syndicate or selling group for a new issue, by definition, cannot be considered "syndicate transactions" for purposes of comparison procedures.
MSRB Rule G-12(f), on automated comparison of inter-dealer transactions, requires dealers to submit for automated comparison all transactions eligible for comparison under National Securities Clearing Corporation's (NSCC) rules and procedures. For transactions by a syndicate manager with syndicate or selling group members, NSCC procedures call for the use of a special "syndicate" submission, which does not require a submission by the contra-side for comparison to occur.[1] Transactions between syndicate managers and dealers that are not members of the syndicate or selling group are not "syndicate transactions" under NSCC's rules and procedures and both the selling and purchasing dealers are required to report its side to the transaction for automated comparison.
Various problems arise in the comparison process if the parties to a trade do not follow the correct procedures for comparison of the trade. Moreover, since the trade report submitted for comparison also serves as the transaction report to the MSRB, identifying a transaction as a "syndicate transaction" in trade reports, when such transaction is not a syndicate transaction under NSCC's rules and procedures, represents a violation of a dealer's obligation to accurately report transactions to the MSRB under Rule G-14.
[1] See "Municipal Bond Selling Group Trades," NSCC Important Notice # 2971 dated April 8, 1988.
