Upcoming Changes to the Real-Time Transaction Reporting System
The MSRB plans to implement several changes to its Real-Time Transaction Reporting System (RTRS) intended to improve the capability of brokers, dealers and municipal securities dealers (collectively “dealers”) to provide the MSRB with a complete and accurate audit trail of all transactions in municipal securities. Beginning November 16, 2009, RTRS will accept a late inter-dealer or customer trade report with a trade date as early as January 2, 2002 and RTRS will accept a cancellation or modification to a previously reported trade up to two years after the trade was reported to RTRS.[1]
While these changes to RTRS increase the timeframe dealers have to report trades late as well as make corrections to previously reported trades, the MSRB reminds dealers of the requirement to review trade status information from RTRS and to correct errors in RTRS submissions promptly.[2] Incorrect submissions to RTRS can result in dissemination of unreliable transaction data to the market until a correction has been submitted to RTRS. Dealers must correct any inaccurate data submitted to RTRS as soon as possible.[3]
Also on November 16, 2009, the National Securities Clearing Corporation (NSCC) subsidiary of the Depository Trust and Clearing Corporation (DTCC) will implement several previously announced changes to its Real-time Trade Matching System (RTTM) including adding the effecting broker symbol (EBS or MPID) to the match criteria for inter-dealer trades.[4] The changes to RTRS described above as well as the changes to RTTM that impact RTRS are reflected in a new version of the Specifications for Real-Time Reporting of Municipal Securities Transactions that also includes other minor technical and clarifying changes.
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Dealers that would like to test the changes to RTRS may do so at this time. Questions about this notice, including instructions on how to make test submissions to RTRS, may be directed to the MSRB Market Information Department at 703-797-6668. Other questions about this notice may be directed to Justin R. Pica, Director, Uniform Practice Policy, at 703-797-6716.
October 21, 2009
[1] Currently, RTRS allows dealers to report a trade late as well as cancel or modify a trade report up to ninety-days after trade date for customer trades and one-year after trade date for inter-dealer trades. As is currently the case in RTRS, only regulatory information about an inter-dealer trade may be modified in RTRS.
[2] See, e.g., Rule G-14 RTRS Procedures (a)(v): “. . . Trade status information from RTRS indicating a problem or potential problem with reported trade data must be reviewed and addressed promptly to ensure that the information being disseminated by RTRS is as accurate and timely as possible.” See also “Reminder Regarding Modification and Cancellation of Transaction Reports: Rule G-14,” MSRB Notice 2005-13 (March 2, 2005) and “Questions and Answers Regarding the Real-Time Transaction Reporting System (RTRS),” MSRB Notice 2005-08 (January 26, 2005), question 15. Of course, a dealer that becomes aware of an error in an RTRS submission without receiving an indication of error from RTRS must also correct such a submission.
[4] See NSCC Important Notice A6886/P&S6456, dated October 9, 2009. MSRB transaction reporting rules currently require dealers that are party to an inter-dealer trade to submit matching information about EBSs and this change to RTTM will enforce this requirement.
