Notice of Filing of Implementation Plan for Real-Time Transaction Reporting System

On November 15, 2004, the Municipal Securities Rulemaking Board (“MSRB”) filed with the Securities and Exchange Commission (“SEC”) the transition details for the January 2005 implementation of the MSRB’s real-time transaction reporting and price dissemination system.[1]  The plan includes a January 31, 2005 effective date for previously approved amendments to Rule G-12(f) and Rule G-14 requiring real-time comparison and trade reporting.[2]  The plan also describes how the transition will be made to the real-time trade reporting system during January, including the start of real-time price dissemination on January 31.  A concurrently dated reminder notice describes dealer system testing requirements that must be completed by in December to ensure a successful implementation of the new system in January.[3]

JANUARY IMPLEMENTATION PLAN

As announced in December 2003, the MSRB is implementing its real-time transaction reporting requirements for brokers, dealers and municipal securities dealers (collectively, “dealers”) in January 2005.[4]   The conversion to real-time transaction reporting requires dealers and the MSRB to implement new systems and procedures for transaction reporting.  Trade reporting will be accomplished through a new MSRB system -- the Real-Time Transaction Reporting System (“RTRS”).  The two major components of RTRS with which dealers will interface are: (i) the RTRS Web Portal for inputting trade data and reviewing the status of trade reports within RTRS; and (ii) the message-based trade input and feedback facility operated by National Securities Clearing Corporation (the “Message Portal”). These are described in the RTRS Operational Plan contained in MSRB Notice 2003-44 and in the RTRS Message Specifications and other explanatory documents subsequently published at www.msrb.org.  

To facilitate a smooth transition to dealer use of the Web Portal and the Message Portal, implementation will occur in two phases on January 10 and January 31, 2005.  Dealers will be required to incorporate use of the RTRS Web Portal into their transaction reporting procedures on January 10, on which date the MSRB also will convert its internal production processing and dealer-feedback systems to RTRS formats.  Accomplishing this transition on January 10 will allow the MSRB and dealers to resolve any implementation issues associated with these system changes prior to the January 31 date for mandatory real-time trade reporting by all dealers.  On January 31, the amendments to Rule G-12(f) and Rule G-14 that require real-time inter-dealer comparison and transaction reporting will become effective, use of the Message Portal will become mandatory, and the MSRB will begin real-time dissemination of trades in transparency reports.

            Further details on the system changes that will occur in January are described below.

January 10, 2005   -- On this date, the MSRB will convert its own production system for processing transaction reports to RTRS.  Dealers will not be required by rule to report in real-time on this date but will be encouraged to do so to ease the transition when real-time reporting becomes mandatory on January 31.  On January 10, the RTRS database will become the “database of record” and dealers will need to employ the RTRS Web browser in their production environment.  It should be noted that dealers that have tested successfully can already convert to real-time comparison and trade reporting procedures, although without all of the “feedback” functionally that will become available in the production environment on January 10.  The MSRB’s conversion to RTRS as the production processing system on January 10 will allow the MSRB to give these dealers full RTRS “feedback” capability on that date.

There will be no change in the timing of transparency reports on January 10.  However, subscribers to the existing transparency reports can begin receiving T+1 reports in the RTRS revised record formats (including the new fields of trade information offered by RTRS) on that date.  The following features of the existing transaction reporting system will be changed or terminated on January 10:

• The old “batch” style formats for reporting inter-dealer and customer trades through NSCC will still be accepted, but the deadline for reporting customer trades will be changed from midnight to 10:00 pm.  The deadline for inter-dealer trade reports will remain 8:00 p.m.

• Because of the MSRB’s change to RTRS as the production processing system, dealers must use 16-digit (rather than 20-digit) control numbers to identify trades, both in real-time and in batch trade reports.  Only 16-digit control numbers will be returned to dealers in message feedback.

• Regardless of whether a dealer is using the new RTRS formats or old batch style formats, the MSRB will discontinue sending “feedback” information in batch files and faxes for customer trades.  Real-time system responses, e-mails and the RTRS Web Portal instead will be available to provide feedback to dealers on their trade reports.

• Dealers who submit their low-volume trade input through the current “TRS dial-up” facility must convert to the RTRS Web Portal by January 10.

January 31, 2005 – On this date, the amendments to Rule G-14, on transaction reporting, and Rule G-12(f), on automated comparison of inter-dealer transactions, will become fully effective, requiring securities transactions to be reported, in most cases, within 15 minutes of the time of trade execution. Use of RTRS trade reporting formats and procedures will become mandatory and the old “batch” style reporting formats will no longer be compliant with Rules G-12(f) and G-14. (The MSRB will discontinue its support of the non-compliant trade reporting methodology soon after January 31.) The MSRB will make real-time transaction price data available to subscribers to its Real-Time Transaction Price Service beginning on this date.

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Questions concerning this notice should be directed to Thomas A. Hutton, Chief Information Officer, at 703-797-6600.

November 17, 2004