SEC Approves Amendments to MSRB Rule G-47
By Ernesto A. Lanza, Chief Regulatory and Policy Officer
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| In July, the Municipal Securities Rulemaking Board received approval from the Securities and Exchange Commission (SEC) on amendments to MSRB Rule G-47, on time of trade disclosure. The amendments provide new time of trade disclosure scenarios and codify, consolidate and retire certain interpretive guidance. The implementation date for the amendments is March 3, 2025. The amendments add new subsection (ii) to Rule G-47(a) clarifying that information that may be material to the transaction would not be required to be disclosed to the customer if such information is intentionally withheld from the dealer’s registered representatives who are engaged in sales to and purchases from customers. This new language would make clear that it is not the MSRB’s intent for dealers to violate federal securities laws. The amendments also add three new time of trade disclosures to Rule G-47 Supplementary Material .03’s non-exhaustive list of specific scenarios that could be material and require a time of trade disclosure: yield to worst; unavailability of official statement for new issue customers; and unavailability of continuing disclosure. Finally, the amendments codify and retire November 2016 interpretive guidance on market discount; codify information from April 1982 interpretive guidance on zero coupon or stepped coupon bonds; retire interpretive guidance from March 1984 on secondary market insurance; and add factor bonds to Rule G-47 Supplementary Material .03(i) as an example of a bond that prepays principal. |
MSRB Makes Filing with SEC
In July, MSRB submitted a proposed rule change for immediate effectiveness to the Securities and Exchange Commission to amend the MSRB’s Real-Time Transaction Reporting System (RTRS) and Price Dissemination Information Facility. The amendments consolidate access by subscribers to the real-time transaction data residing within RTRS through a web service and fully retire the Transmission Control Protocol secure socket connection.
Have a compliance question? Send your inquiry to the MSRB at compliance@msrb.org.
Compliance Calendar
Dealers and municipal advisors should note the following key compliance dates and deadlines.
October 1, 2024 - First day to file G-37 for quarter ending September 30
October 15, 2024 - Deadline for dealers to submit remote office inspection year 1 data to FINRA
October 31, 2024 - Last day to file G-37 for quarter ending September 30
- Last day to make timely payment for annual registration fee under Rule A-12
December 27, 2024 - Notification deadline for dealers to withdraw from remote office inspection year 2 pilot
December 31, 2024 - End of 529 underwriting assessment reporting period
- Last day for dealers to complete annual review and testing of supervisory controls
- Last day for municipal advisors to complete annual CEO certification and municipal advisor continuing education
- Last day to complete regulatory element content for municipal securities representatives and principals
January 1, 2025 - First day of Form A-12 annual affirmation period
- First day to file Form G-37 for quarter ending Dec 31
January 31, 2025 - Last day of Form A-12 annual affirmation period
March 1, 2025 - Last day to submit Form G-45 report for semi-annual reporting period ending December 31, 2024 (including performance data)
March 3, 2025 - Compliance date for amendments to Rule G-47
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