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Interpretive Guidance -
Publication date:
Time of Trade Disclosures in Inter-Dealer Transactions
Rule Number:

Rule G-47

For inter-dealer transactions, there is no specific requirement for brokers, dealers or municipal securities dealers (individually and collectively, “dealers”) to disclose all material facts to another dealer at time of trade. A selling dealer is not generally charged with the responsibility to ensure that the purchasing dealer knows all relevant features of the municipal securities being offered for sale. The selling dealer may rely, at least to a reasonable extent, on the fact that the purchasing dealer is also a professional and will satisfy their need for information prior to entering into a contract for the municipal securities.
 
The items of information that professionals in an inter-dealer transaction must exchange at or prior to the time of trade are governed by principles of contract law and essentially are those items necessary adequately to describe the municipal security that is the subject of the contract. As a general matter, these items of information do not encompass all material facts, but should be sufficient to distinguish the municipal security from other similar issues. The Board has interpreted Rule G-17 to require dealers to treat other dealers fairly and to hold them to the prevailing ethical standards of the industry. The rule also prohibits dealers from knowingly misdescribing municipal securities to another dealer. As a result, it is possible that non-disclosure of an unusual feature might constitute an unfair practice and thus become a violation of Rule G-17 even in an inter-dealer transaction.
 
For example, with respect to bonds that prepay principal, non-disclosure of the fact that a bond prepays principal could be a violation of Rule G-17. This would be especially true if the information about the prepayment feature is not accessible to the market and is intentionally withheld by the selling dealer. Whether or not non-disclosure constitutes an unfair practice in a specific case would depend upon the individual facts of the case. However, to avoid trade disputes and settlement delays in inter-dealer transactions, it generally is in dealers’ interest to reach specific agreement on the existence of any prepayment feature and the amount of unpaid principal that will be delivered.

 
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Notice 2025-04 - Informational Notice
Publication date:
Delayed Announcement of Effective Date for Amendment to MSRB Rule G-14 to Shorten Timeframe for Reporting Transactions in Municipal Securities
Information for:

General Public, Investors

Rule Number:

Rule G-12, Rule G-14, IF-1

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Notice 2025-02 - Request for Comment
Publication date: | Comment due:
Concept Release: MSRB Requests Comment on a Municipal Securities Pre-Trade Data Initiative [Withdrawn]
Information for:

Bank Dealers, Dealers, General Public, Investors

No comments received.

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Notice 2025-01 - Informational Notice
Publication date:
Notice Concerning Trades Effected on January 9, 2025 – National Day of Mourning for Former President James Earl Carter, Jr.
Information for:

Dealers, General Public, Investors

Rule Number:

Rule G-14

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Notice 2024-15 - Request for Comment
Publication date: | Comment due:
Concept Release: MSRB Requests Comment on Potential Modernization of Municipal Fund Securities Disclosure Obligations
Information for:

Dealers, General Public, Investors, Issuers, Municipal Advisors

Rule Number:

Rule G-17, Rule G-32, Rule G-47

Submit Comments
  1. ABLE Savings Plan Network: Letter from Bette Ann Mobley, Chair, dated April 10, 2025
  2. Arizona State Treasurer’s Office: Letter from Kimberly Yee, Treasurer, dated April 10, 2025
  3. Ascensus: Letter from Christal Fenton, Associate General Counsel, dated April 10, 2025
  4. Bank of North Dakota: Email from James Barnhardt dated April 3, 2025
  5. College Savings Foundation: Letter from Chris McGee, Chair, dated April 9, 2025
  6. College Savings Plans Network: Letter from Mary G. Morris, Chair, dated April 2, 2025
  7. Commonwealth Savers Plan: Letter from Mary G. Morris, Chief Executive Officer, dated April 11, 2025
  8. Investment Company Institute:  Letter from Tara Buckley, Deputy General Counsel, Financial Regulation, and Shannon Salinas, Associate General Counsel, Retirement Policy, dated April 11, 2025
  9. Illinois State Treasurer’s Office: Letter from Michael W. Frerichs, Treasurer, dated April 10, 2025
  10. Massachusetts Educational Financing Authority: Letter from Thomas M. Graf, Executive Director, dated April 9, 2025
  11. my529: Letter from Richard K. Ellis, Executive Director, dated March 31, 2025
  12. Nebraska State Treasurer’s Office: Letter from Rachel Biar, Deputy State Treasurer for Savings Programs, dated April 2, 2025
  13. Pennsylvania Treasury Department: Letter from Stacy Garrity, Treasurer, dated April 2, 2025
  14. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Gerald O’Hara, Vice President and Assistant General Counsel, dated April 11, 2025
  15. TIAA-CREF Tuition Financing, Inc: Letter from Christopher S. Lynch, President, dated April 10, 2025
  16. Vestwell: Letter from Aaron Schumm, Chief Executive Officer, dated April 11, 2025
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Notice 2024-14 - Request for Comment
Publication date: | Comment due:
Request for Information on the MSRB’s Rate Card Process
Information for:

Dealers, General Public, Municipal Advisors

All Comments to Notice 2024-14

  1. American Securities Association: Letter from Jessica R. Giroux, General Counsel and Head of Fixed Income Policy, dated January 28, 2025
  2. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated January 28, 2025
  3. ICE Bonds Securities Corporation: Letter from Robert Laorno, General Counsel, dated January 21, 2025
  4. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 28, 2025
  5. Public Resources Advisory Group, Inc.: Letter from Thomas F. Huestis, Senior Managing Director, dated January 27, 2025
  6. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Gerald O’Hara, Vice President and Assistant General Counsel, dated January 28, 2025
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Notice 2024-13 - Informational Notice
Publication date:
MSRB Seeks Volunteers for Advisory Groups Including a New Group on Technology
Information for:

Dealers, General Public, Investors, Issuers, Municipal Advisors

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Notice 2024-12 - Approval Notice
Publication date:
SEC Approves Amendments to MSRB Rule G‐14 to Shorten Timeframe for Reporting Transactions in Municipal Securities
Information for:

Dealers, General Public, Investors

Rule Number:

Rule G-12, Rule G-14, IF-1

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Notice 2024-09 - Request for Comment
Publication date: | Comment due:
Request for Comment on Gathering and Display of Bank Dealer Associated Persons’ Registration and Qualification Information
Information for:

Bank Dealers, General Public, Investors

Rule Number:

Rule G-7, Rule A-12

All Comments to Notice 2024-09

  1. Association of Registration Management, Inc.: Letter from Richard Izzo, President, dated August 5, 2024
  2. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated August 5, 2024
  3. Frost Bank Capital Markets Division: Letter from Jeff Beckel, SEVP and Director of Capital Markets, dated July 30, 2024
  4. Frost Bank Capital Markets Division: Email from Trevor Cross dated July 30, 2024
  5. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, Head of Municipal Securities, dated August 5, 2024
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Notice 2024-08 - Informational Notice
Publication date:
MSRB Amends Rule G-27 to Allow Dealers to Conduct Remote Inspections, Consistent with Recent FINRA Amendments
Information for:

Dealers, General Public, Investors, Issuers

Rule Number:

Rule G-27

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Notice 2024-07 - Informational Notice
Publication date:
MSRB to Retire Select Interpretive Guidance Regarding Inter-Dealer Confirmation Disclosures
Information for:

Bank Dealers, Dealers, General Public, Investors

Rule Number:

Rule G-12, Rule G-15

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Notice 2024-06 - Informational Notice
Publication date:
MSRB Amends Rule G-27 to Adopt the Residential Supervisory Location Classification Consistent with FINRA Dealer Supervision Provisions
Information for:

Dealers, General Public, Investors, Issuers

Rule Number:

Rule G-27

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Notice 2023-11 - Request for Comment
Publication date: | Comment due:
Request for Information on Impacts of MSRB Rules on Small Firms
Information for:

Dealers, General Public, Municipal Advisors

All Comments to Notice 2023-11

  1. Advisabilitys: Email from Andrew Boyack dated January 9, 2024
  2. Academy Securities, Inc.: Letter from Michael Boyd, Chief Compliance Officer, dated February 23, 2024
  3. American Securities Association: Letter from Jessica R. Giroux, General Counsel, dated February 26, 2024
  4. Amuni Financial, Inc.: Letter from Mike Petagna, President, dated January 8, 2024
  5. Anonymous: Letter
  6. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated February 26, 2024
  7. Clary Consulting Company: Email from Lowell Clary dated February 16, 2024
  8. Derivative Advisors: Letter from Elaine M. Philbrick, Principal, dated December 6, 2023
  9. Dixworks, LLC: Email from Dennis Dix, Jr. dated February 9, 2024
  10. Echo Valley Advisors, LLC: Letter from Julie Needham, President, dated February 23, 2024
  11. Herold & Lantern Investments: Letter from Brad Harris, Director of Fixed Income – Municipal Bonds
  12. Municipal Capital Markets Group, Inc.: Letter from Fred R. Cornwall, President, dated February 26, 2024
  13. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated February 26, 2024
  14. Regional Brokers, Inc.: Letter from H. Deane Armstrong, CCO, dated February 26, 2024
  15. Ridgeline Municipal Strategies, LLC: Email from Dmitry Semenov dated December 29, 2023
  16. Sanderlin Securities LLC: Letter from Matthew Kamler, President, dated January 26, 2024
  17. Searle & Co., Inc.: Letter from Robert S. Searle, President, dated February 16, 2024
  18. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, Head of Municipal Securities, dated February 26, 2024
  19. Shnayder, Yana: Email dated December 13, 2023
  20. Siebert Williams Shank & Co., LLC: Letter from Suzanne Shank, President & Chief Executive Officer, and Gary Hall, President of Infrastructure & Public Finance, dated February 26, 2024
  21. Speer Financial, Inc.: Letter from Daniel Forbes, President, dated February 20, 2024
  22. Stern Brothers: Letter dated February 26, 2024
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Notice 2023-08 - Request for Comment
Publication date: | Comment due:
Request for Comment on Retrospective Rule Review of Rule G-12(c) on Inter-Dealer Confirmations and Related Interpretive Guidance
Information for:

Bank Dealers, Dealers, General Public, Investors

Rule Number:

Rule G-12

  1. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated December 15, 2023
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Notice 2023-03 - Approval Notice
Publication date:
SEC Approves New MSRB Rule G-46 on Duties of Solicitor Municipal Advisors and Related Amendments to MSRB Rule G-8
Information for:

General Public, Issuers, Municipal Advisors

Rule Number:

Rule G-8, Rule G-46

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Notice 2023-02 - Request for Comment
Publication date: | Comment due:
Request for Comment Regarding a Retrospective Review of the MSRB’s Time of Trade Disclosure Rule and Draft Amendments to MSRB Rule D-15, On Sophisticated Municipal Market Professionals
Information for:

Dealers, General Public, Investors

Rule Number:

Rule G-47, Rule D-15

All Comments to Notice 2023-02

  1. AKF Consulting: Letter from Andrea Feirstein, Managing Director, and Mark Chapleau, Senior Consultant, dated April 20, 2023
  2. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated April 17, 2023
  3. College Savings Plans Network: Letter from Rachel Biar, Nebraska Assistant State Treasurer, NEST 529 College Savings Program Director, Chairman, College Savings Plans Network, dated April 17, 2023
  4. Government Finance Officers Association: Letter from Emily Brock, Director, Federal Liaison Center, dated July 21, 2023
  5. McLane, Curtis: Email dated April 19, 2023
  6. my529: Letter from Richard K. Ellis, Executive Director, dated April 17, 2023
  7. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, Head of Municipal Securities, dated April 17, 2023
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Notice 2022-08 - Approval Notice
Publication date:
SEC Approves Amendments to Rule G-34 to Better Align the CUSIP Requirements for Underwriters and Municipal Advisors with Current Market Practices
Information for:

Bank Dealers, Dealers, Investors, Municipal Advisors

Rule Number:

Rule G-34

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Compliance Resource
Publication date:
G-32 Form Updates
Information for:

Dealers, Investors

Rule Number:

Rule G-32

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Compliance Resource
Publication date:
Summary Table of New Fields for Amended Form G-32
Information for:

Bank Dealers, Dealers, Investors

Rule Number:

Rule G-32

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Compliance Resource
Publication date:
Frequently Asked Questions About Form G-32
Information for:

Dealers, Investors

Rule Number:

Rule G-32

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Compliance Resource
Publication date:
LIBOR Transition Information
Information for:

Dealers, General Public, Investors, Issuers, Municipal Advisors

Rule Number:

Rule G-17, Rule G-42

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Compliance Resource
Publication date:
Resources Related to 2019 Municipal Securities Examination Priorities
Information for:

Bank Dealers, Dealers, General Public, Investors, Issuers, Municipal Advisors

Rule Number:

Rule G-2, Rule G-3, Rule G-8, Rule G-15, Rule G-17, Rule G-19, Rule G-21, Rule G-27, Rule G-30, Rule G-34, Rule G-40, Rule G-42, Rule A-12

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