Select regulatory documents by category:
Bank Dealers, Dealers, Municipal Advisors
1. Bernardi Securities: Letter from Eric Bederman, Chief Operating and Compliance Officer, dated December 26, 2014
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated January 20, 2015
3. Coastal Securities: Letter from Chris Melton, Executive Vice President, dated January 16, 2015
4. Consumer Federation of America: Letter from Micah Hauptman, Financial Services Counsel, dated January 20, 2015
5. DelphX LLC: Letter from Larry E. Fondren, President and CEO, dated January 7, 2015
6. Diamant Investment Corporation: Letter from Herbert Diamant, President, dated January 9, 2015
7. Fidelity Investments: Letter from Norman L. Ashkenas, Chief Compliance Officer, Fidelity Brokerage Services, LLC, and Richard J. O'Brien, Chief Compliance Officer, National Financial Services, LLC, dated January 20, 2015
8. Financial Information Forum: Letter from Darren Wasney, Program Manager, dated January 20, 2015
9. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated January 20, 2015
10. Financial Services Roundtable: Letter from Rich Foster, Vice President and Senior Counsel for Regulatory and Legal Affairs, dated January 20, 2015
11. Gerald Heilpern: E-mail dated December 9, 2014
12. Gerald Heilpern: E-mail dated December 18, 2014
13. Gerald Heilpern: E-mail dated January 8, 2015
14. Hilliard Lyons: Letter from Alexander I. Rorke, Senior Managing Director, Municipal Securities Group, dated January 20, 2015
15. Hutchinson Shockey Erley & Co.: Letter from Thomas E. Dannenberg, President and CEO, dated January 20, 2015
16. Interactive Data: Letter from Andrew Hausman, President, Pricing and Reference Data, dated January 20, 2015
17. John Smith: E-mail dated December 10, 2014
18. Jorge Rosso: E-mail dated November 24, 2014
19. Karin Tex: Letter dated January 12, 2015
20. McLiney And Company: Email from George J. McLiney, Jr. dated December 22, 2014
21. Morgan Stanley Smith Barney LLC: Letter from Vincent Lumia, Managing Director, dated January 20, 2015
22. Nathan Hale Capital, LLC: Letter from Peter G. Brandel, Senior Vice President, Municipal Bond Trading, and Kenneth T. Kerr, Senior Vice President, Municipal Bond Trading, dated January 20, 2015
23. Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated January 20, 2015
24. Private Citizen: E-mail dated November 23, 2014
25. R. Seelaus & Co., Inc.: Letter from Richard Seelaus dated January 8, 2015
26. RW Smith & Associates, LLC: E-mail from Paige Pierce dated January 21, 2015
27. Securities Industry and Financial Markets Association: Letter from Sean Davy, Managing Director, Capital Markets Division, and David L. Cohen, Managing Director and Associate General Counsel, Municipal Securities Division, dated January 20, 2015
28. Standard & Poor's Securities Evaluations, Inc.: Letter from Gregory Carlin, Vice President, dated January 20, 2015
29. Thomson Reuters: Letter from Kyle C. Wootten, Deputy Director - Compliance and Regulatory, dated January 16, 2015
30. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated January 20, 2015
Bank Dealers, Dealers, Municipal Advisors
1. Anonymous: Letter
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated December 8, 2014
3. Chris Taylor: E-mail dated October 23, 2014
4. FCS Group: E-mail from Taree Bollinger dated October 24, 2014
5. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated December 5, 2014
6. National Association of Municipal Advisors: Letter from Terri Heaton, President, dated December 8, 2014
7. PFM Group: Letter from Joseph J. Connolly, Counsel, dated November 7, 2014
8. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated December 8, 2014
Bank Dealers, Dealers, Municipal Advisors
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated October 23, 2014
2. Financial Services Institute: Letter from David T. Bellaire, Executive Vice President and General Counsel, dated October 23, 2014
3. Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated October 23, 2014
4. Kevin M. Bronner: Letter dated September 27, 2014
5. Office of the Investor Advocate, United States Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated October 31, 2014
6. PRISM Municipal Advisors: E-mail from Bradford Sprague dated September 8, 2014
7. Public Financial Management, Inc.: Letter from John H. Bonow, Chief Executive Officer, dated October 31, 2014
8. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director and Associate General Counsel, dated October 23, 2014
Bank Dealers, Dealers, Municipal Advisors
1. American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated October 1, 2014
2. Anonymous: E-mail dated October 1, 2014
3. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated October 1, 2014
4. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated October 8, 2014
5. Caplin & Drysdale: Letter from Trevor Potter and Matthew T. Sanderson dated September 30, 2014
6. Castle Advisory Company LLC: E-mail from Stephen Schulz dated August 18, 2014.
7. Center for Competitive Politics: Letter from Allen Dickerson, Legal Director, dated October 1, 2014
8. Dave A. Sanchez: Letter dated November 5, 2014
9. Hardy Callcott: E-mail dated September 9, 2014
10. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated October 1, 2014
11. Public Citizen, et. al.: Letter dated October 1, 2014 from Bartlett Naylor, Financial Policy Advocate, and Craig Holman, Government Affairs Lobbyist, Public Citizen; Ron Fein, Legal Director, Free Speech for People; John Harrington, President, Harrington Investments, Inc.; New Progressive Alliance; American Federation of State, County and Municipal Employees; ReFund America Project at the Roosevelt Institute; U.S. PIRG; Consumer Federation of America; and Americans for Financial Reform
12. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 30, 2014
13. WM Financial Strategies: Letter from Joy A. Howard, Principal, dated October 1, 2014
Bank Dealers, Dealers
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated September 26, 2014
2 Financial Information Forum: Letter from Darren Wasney, Program Manager, dated September 19, 2014
3. Herbert Murez: E-mail dated August 13, 2014
4. Income Securities Advisor Inc.: E-mail from Richard Lehmann dated August 26, 2014
5. Loren Trigo: E-mail dated August 13, 2014
6. RW Smith & Associates, LLC: E-mail from Paige W. Pierce, President and Chief Executive Officer, dated September 26, 2014
7. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 25, 2014
1. American Bankers Association: Letter from Cristeena Naser, Vice President, Center for Securities, Trust & Investments, dated August 25, 2014
2. American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated August 25, 2014
3. Bart Leary: E-mail dated July 23, 2014
4. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated August 25, 2014
5. Columbia Capital Management, LLC: Letter from Jeff White, Principal, dated August 25, 2014
6. Dave A. Sanchez: Letter dated August 25, 2014
7. Financial Services Roundtable: Letter from Richard Foster, Vice President and Senior Counsel for Regulatory and Legal Affairs, dated August 25, 2014
8. Florida Division of Bond Finance: Letter from J. Ben Watkins III, Director, dated August 22, 2014
9. Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liaison Center, dated September 2, 2014
10. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated August 19, 2014
11. Lewis Young Robertson & Burningham, Inc.: Letter from Laura D. Lewis, Principal, dated August 25, 2014
12. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated August 25, 2014
13. New York State Bar Association, Business Law Section, Securities Regulation Committee: Letter from Peter W. LaVigne, Chair of the Committee, dated August 27, 2014
14. Piper Jaffray: Letter from Frank Fairman, Managing Director, Head of Public Finance Services, dated August 25, 2014
15. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated August 25, 2014
16. Southern Municipal Advisors, Inc.: Letter from Michael C. Cawley, Senior Consultant, dated August 25, 2014
17. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated August 25, 2014
18. WM Financial Strategies: Letter from Joy A. Howard, Principal, dated August 25, 2014
19. Zions First National Bank: Letter from W. David Hemingway, Executive Vice President, dated August 25, 2014
Bank Dealers, Dealers, Municipal Advisors
1. Arrow Partners: Letter from Steven Rubenstein dated May 16, 2014
2. Association of Registration Management: Letter from Michele Van Tassel, President, dated May 16, 2014
3. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated May 16, 2014
4. Cedar Partners Ltd: Letter from Christy Ping, Director/Chief Compliance Officer, dated May 16, 2014
5. Central States Capital Markets: E-mail from Mark Detter dated April 17, 2014
6. CFA Institute: Letter from Inigo Bengoechea, Director, and Dan Larocco, Manager, dated April 25, 2014
7. Compass Securities Corporation: Letter from John R. Ahern, President
8. Dixworks LLC: E-mail from Dennis Dix, Jr. dated April 11, 2014
9. Fitzgibbon Toigo Associates, LLC: E-mail from Brian X. Fitzgibbon dated May 16, 2014
10. Fortress Group, Inc.: Letter from Bruce A. Williamson, Managing Director and Chief Compliance Officer, dated May 16, 2014
11. Frank Taylor: E-mail dated March 19, 2014
12. George K. Baum & Company: Letter from Guy E. Yandel, EVP Public Finance, Dana L. Bjornson, EVP and Chief Compliance Officer, and Andrew F. Sears, SVP and General Counsel, dated May 16, 2014
13. Government Credit Corporation: E-mail from Joseph Mooney dated March 18, 2014
14. Hamersley Partners, LLC: Letter from Andrew Phillips, Principal and CCO, dated May 16, 2014
15. IMMS LLC: E-mail from John Daly dated May 16, 2014
16. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated May 8, 2014
17. Jorge Rosso: E-mail dated April 3, 2014
18. Monahan & Roth, LLC: Letter from Lisa Roth, President, dated May 16, 2014
19. MVision Private Equity Advisers USA LLC: Letter from Victoria Sherliker, General Counsel, dated May 16, 2014
20. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated May 16, 2014
21. New Albany Capital Partners, LLC: Letter from Rick Wayman dated May 14, 2014
22. Oyster River Capital LP: Letter from Richard A. Murphy dated May 16, 2014
23. Perkins Fund Marketing LLC: Letter from Gilman C. Perkins, Principal and Managing Member, dated May 16, 2014
24. Raftelis Financial Consultants, Inc.: Letter from Alexis F. Warmath, Vice President, and Christopher P.N. Woodcock, President, Woodcock & Associates, Inc., dated May 16, 2014
25. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated May 16, 2014
26. Sonja Sullivan: E-mail dated May 16, 2014
27. Stacy Havener: E-mail dated May 16, 2014
28. Stonehaven: Letter from Steven Jafarzadeh, Managing Director and Partner, dated May 16, 2014
29. Tessera Capital Partners: Letter from Donna DiMaria, CEO/CCO, dated May 16, 2014
30. Third Party Marketers Association: Letter from Donna DiMaria, Chairman of the Board of Directors, dated May 16, 2014
31. Tibor Partners Inc.: E-mail from William Johnston dated March 18, 2014
32. Timothy D. Wasson: Letter
33. Yuba Group: Letter from Linda Fan, Managing Partner, dated April 28, 2014
34. Zions First National Bank: Letter from W. David Hemingway, Executive Vice President, dated May 16, 2014
35. Zions First National Bank: Letter from James G. Livingston, Senior Vice President, dated May 16, 2014
1. American Bankers Association: Letter from Cristeena G. Naser, Vice President and Senior Counsel, dated May 1, 2014
2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated April 28, 2014
3. Edwin C. Blitz Investments, Inc.: E-mail from Edwin Blitz dated March 18, 2014
4. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated April 15, 2014
5. LIATI Group, LLC: E-mail from Weldon Fleming dated March 10, 2014
6. MSA Professional Services, Inc.: Letter from Gilbert A. Hantzsch, Chief Executive Officer, dated April 28, 2014
7. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated April 28, 2014
8. Raftelis Financial Consultants, Inc.: Letter from Alexis F. Warmath, Vice President, and Christopher P.N. Woodcock, President, Woodcock & Associates, Inc., dated April 28, 2014
9. Roberts Consulting, LLC: E-mail from Jonathan Roberts dated March 13, 2014
10. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated April 25, 2014
11. Tibor Partners Inc.: E-mail from William Johnston dated February 25, 2014
12. Yuba Group: Letter from Linda Fan, Managing Partner, dated April 28, 2014
Bank Dealers, Dealers
1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated March 21, 2014
2. City of New York, Office of the Comptroller: Letter from Scott M. Stringer, New York City Comptroller, dated March 21, 2014
3. Coastal Securities: Letter from Chris Melton, Executive Vice President, dated March 21, 2014
4. Interactive Data: Letter from Andrew Hausman, President, dated March 21, 2014
5. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated March 21, 2014
6. NYSE Euronext: Letter from Martha Redding, Chief Counsel, dated March 31, 2014
7. Regional Brokers, Inc.: Letter from H. Deane Armstrong, CCO
8. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated March 13, 2014
9. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated April 2, 2014
10. Wulff, Hansen & Co.: Letter from Chris Charles, President, dated March 21, 2014
1. Acacia Financial Group, Inc.: Letter from Kim M. Whelan, Co-President, dated March 10, 2014
2. American Bankers Association: Letter from Cristeena G. Naser, Vice President and Senior Counsel, dated March 4, 2014
3. American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated March 7, 2014
4. American Public Transportation Association: Letter from Michael P. Melaniphy, President and CEO, dated March 10, 2014
5. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated March 10, 2014
6. Cape Cod Five Cents Savings Bank: Letter from Dorothy A. Savarese, President and Chief Executive Officer
7. Chancellor Financial Associates: E-mail from William J. Caraway, President, dated January 14, 2014
8. Coastal Securities: Letter from Chris Melton, Executive Vice President, dated March 10, 2014
9. College Savings Foundation: Letter from Mary G. Morris, Chair, dated March 10, 2014
10. College Savings Plans Network: Letter from Betty Everitt Lochner, Director, Guaranteed Education Tuition Program, dated March 10, 2014
11. Cooperman Associates: Letter from Joshua G. Cooperman dated March 10, 2014
12. Erika Miller: E-mail dated February 4, 2015
13. FCS Group: Letter from Taree Bollinger, Vice President, dated March 17, 2014
14. First River Advisory L.L.C.: Letter from Shelley J. Aronson, President, dated January 16, 2014
15. First Southwest Company: Letter from Hill A. Feinberg, Chairman and Chief Executive Officer, and Michael G. Bartolotta, Vice Chairman, dated March 7, 2014
16. Frost Bank: Letter from William H. Sirakos, Senior Executive Vice President, dated March 10, 2014
17. George K. Baum & Company: Letter from Guy E. Yandel, EVP and Head of Public Finance, Dana L. Bjornson, EVP, CFO and Chief Compliance Officer, and Andrew F. Sears, SVP and General Counsel, dated March 10, 2014
18. Government Finance Officers Association: Letter from Dustin McDonald, Director, Federal Liasion Center, dated March 13, 2014
19. Government Investment Officers Association: Letter from Laura Glenn, President, et. al., dated March 7, 2014
20. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated March 4, 2014
21. J.P. Morgan: Letter from Paul N. Palmeri, Managing Director, dated March 10, 2014
22. Kutak Rock LLP: Letter from John J. Wagner dated March 10, 2014
23. Lamont Financial Services Corporation: Letter from Robert A. Lamb, President, dated March 10, 2014
24. Lewis Young Robertson & Burningham, Inc.: Letter from Laura D. Lewis, Principal, dated March 3, 2014
25. MSA Professional Services, Inc.: Letter from Gilbert A. Hantzsch, CEO, dated March 10, 2014
26. National Association of Bond Lawyers: Letter from Allen K. Robertson, President, dated March 18, 2014
27. National Association of Health and Educational Facilities Finance Authorities: Letter from Pamela Lenane, President, David J. Kates, Chapman and Cutler LLP, and Charles A. Samuels, Mintz Levin, dated March 10, 2014
28. National Association of Independent Public Finance Advisors: Letter from Jeanine Rodgers Caruso, President, dated March 10, 2014
29. National Healthcare Capital LLC: Letter from Richard Plumstead
30. New York State Bar Association, Business Law Section, Securities Regulation Committee: Letter from Peter W. LaVigne, Chair of the Committee, dated March 12, 2014
31. Northland Securities, Inc.: Letter from John R. Fifield, Jr., Director of Public Finance/Senior Vice President, dated March 7, 2014
32. Oppenheimer & Co. Inc.: E-mail from John Rodstrom dated March 10, 2014
33. Parsons Brinckerhoff Advisory Services, Inc.: Letter from Mark E. Briggs, President, dated March 10, 2014
34. Piper Jaffray: Letter from Frank Fairman, Managing Director, Head of Public Finance Services, dated March 10, 2014
35. Public Financial Management, Inc.: Letter from John H. Bonow, Chief Executive Officer, dated March 10, 2014
36. Public Resources Advisory Group: Letter from Thomas Huestis dated March 10, 2014
37. Raftelis Financial Consultants, Inc.: Letter from Lex Warmath dated March 10, 2014
38. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 10, 2014
39. Sutherland Asbill & Brennan LLP: Letter from Michael B. Koffler dated March 10, 2014
40. Wells Fargo Advisors, LLC: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated March 10, 2014
41. Winters & Co. Advisors, LLC: Letter from Christopher J. Winters dated March 10, 2014
42. WM Financial Strategies: Letter from Joy A. Howard, Principal, dated March 10, 2014
43. Woodcock & Associates, Inc.: E-mail from Christopher Woodcock dated January 14, 2014
44. Wulff, Hansen & Co.: Letter from Chris Charles, President, dated March 17, 2014
45. Yuba Group: Letter from Linda Fan, Managing Partner, dated March 7, 2014
46. Zions First National Bank: Letter from W. David Hemingway, Executive Vice President, dated March 10, 2014
Executing Broker Symbols: Rule G-14
MSRB Rule G-14 on Transaction Reporting requires that every dealer obtain an executing broker symbol, if one has not already been assigned, from National Association of Securities Dealers Automated Quotations (NASDAQ). NASDAQ will assign executing broker symbols to all dealers including bank dealers. NASDAQ Subscriber Services can be reached at 212-231-5180, option 3. When calling NASDAQ Subscriber Services for an executing broker symbol, dealers should state that they need the symbol for use in reporting transactions in municipal securities to the MSRB. If dealers experience difficulties in obtaining executing broker symbols, then they can send an e-mail to subscriber@NASDAQ.com.
NOTE: This notice was revised to reflect updated information.
Review and Approval of Customer Accounts
Review and approval of customer accounts. This is in response to your letter dated July 24, 1996, requesting an interpretation of rule G-27(c)(iii) on written supervisory procedures.
Rule G-27(c)(iii) requires that each municipal securities dealer adopt, maintain and enforce written supervisory procedures ensuring the "regular and frequent" review and approval by a designated principal of customer accounts introduced or carried by the dealer in which transactions in municipal securities are effected. The rule further states that such review shall be designed to ensure that such transactions are in accordance with all applicable rules and to detect and prevent irregularities and abuses.
Because circumstances vary from dealer to dealer, the Board has not specified a time period to define "regular and frequent" for purposes of rule G-27(c)(iii). As you can see, however, the purpose of this provision is to detect and prevent irregularities and abuses that may occur in customer accounts. The Board expects dealers to establish procedures that effectively obtain this objective and that are capable of compliance. While the Board has never specifically addressed "risk-focussed" methods for determining periodic account review, the Board has stated that, in determining when an account must be reviewed, a dealer might look to the volume and frequency of trading and the nature of the securities traded. The Board noted that account review guidelines based on these factors would be appropriate if they are articulated clearly in a dealer's written supervisory procedures.[1] MSRB interpretation of August 7, 1996.
[1] Supervision Requirements, MSRB Reports, Vol. 10, No. 2 (May 1990) at 6.
Rule G-14 Transaction Reporting Procedures-Time of Trade Reporting
1. Q: When is the inter-dealer time of trade reporting requirement effective?
A: The amendment to the rule G-14 transaction reporting procedures requiring the submission of time of trade execution for inter-dealer transactions became effective on July 1, 1996.
2. Q: What is the purpose of submitting the time of trade to the Board?
A: The Board's Transaction Reporting Program has two functions - public dissemination of price and volume information about frequently traded securities and the maintenance of a surveillance database to assist regulators in inspection for compliance with, and enforcement of, Board rules and securities laws. The surveillance database includes, among other things, the price and volume of each reported transaction, the trade date, the identification of the security traded, and the parties to the trade. The addition of the time of trade execution will enable the enforcement agencies to construct audit trails of inter-dealer transactions. When customer transactions are added to the system in 1998, these transaction records also will include time of trade. Time of trade will not be made public.
3. Q: How is time of trade reported?
A: Under rule G-14, inter-dealer transaction information is reported to the Municipal Securities Rulemaking Board using the same system used for automated comparison of inter-dealer transactions, operated by National Securities Clearing Corporation. Rule G-14 requires that the transaction information be submitted in the format specified by NSCC, and within such timeframe as required by NSCC to produce a compared trade for the transaction in the initial comparison cycle on the night of trade date. A broker, dealer or municipal securities dealer may employ an agent that is a member of NSCC or a registered clearing agency for the purpose of submitting transaction information. For example, the clearing broker generally reports transactions to the MSRB through NSCC when there is an introducing/clearing broker arrangement.
Under the new amendment to rule G-14, the transaction information submitted in accordance with the rule G-14 procedures must include the time of trade execution. NSCC has provided a space designated for this purpose in the standard format used for submitting trade data into the automated comparison system.
4. Q: Which dealer in an inter-dealer transaction reports the time of trade?
A: Under NSCC's automated comparison procedures, both sides of a transaction generally are required to submit transaction information. Therefore, time of trade will be reported by each side of the transaction in most cases. For "syndicate take-down" transactions, which are reported by only the seller, the time of trade is reported only by the seller.
5. Q: If the time of trade that I submit does not agree with the time of trade that the contra party submits, will this cause the trade not to compare?
A: No. The time of trade is not a match item in the automated comparison system.
6. Q: Why do both sides to the transaction have to submit the time of trade?
A: In some cases, even though both sides of a transaction are supposed to submit transaction information, the Board receives transaction information from only one party to a transaction. This may occur, for example, when a dealer "stamps an advisory" to create a compared trade. It therefore is necessary for each side of a transaction to report the time of trade to ensure that the surveillance data base has at least one report of the time of trade.
7. Q: Does the time of trade reporting requirement apply only to secondary market transactions?
A: No. The time of trade is required for all inter-dealer transactions including those in the primary market.
8. Q: How does a dealer determine the time of trade for transactions?
A: In general, this is the same time as the "time of execution," as currently required for recordkeeping purposes under rule G-8(a)(vi) and (vii).
9. Q: What is the time of trade for syndicate allocations on new issues?
A: First it should be noted that the "initial trade date" for an issue of municipal securities cannot precede the date of award (for competitive issues) or the date that the bond purchase agreement is signed (for negotiated issues). See rule G-34(a)(ii)(C)(2) and MSRB Interpretations of April 30, 1982, MSRB Manual and October 7, 1982, MSRB Manual. Similarly, the time of trade may not precede the time of award (for competitive issues) or the time that the bond purchase agreement is signed (for negotiated issues). In the typical case involving a competitive issue in which allocations are made after the date of award, the time of trade execution is the time that the allocation is made. If allocations have been "preassigned," prior to a competitive award, or prior to the signing of a bond purchase agreement, the time of award or signing of the bond purchase agreement should be entered as the "time of trade."
