[Federal Register Volume 90, Number 117 (Friday, June 20, 2025)]
[Notices]
[Pages 26390-26399]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-11292]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-103262; File No. SR-MSRB-2025-01]
Self-Regulatory Organizations; Municipal Securities Rulemaking
Board; Notice of Filing of a Proposed Rule Change To Amend Rule G-14
RTRS Procedures under MSRB Rule G-14 Regarding the Timing of Reporting
Transactions in Municipal Securities to the MSRB and To Make a Related
Amendment to Rule G-12
June 16, 2025.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'' or ``Exchange Act'') \1\ and Rule 19b-4 thereunder,\2\ notice
is hereby given that on June 10, 2025, the Municipal Securities
Rulemaking Board (``MSRB'' or ``Board'') filed with the Securities and
Exchange Commission (``SEC'' or
[[Page 26391]]
``Commission'') the proposed rule change as described in Items I, II,
and III below, which Items have been prepared by the MSRB. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
The MSRB filed with the Commission a proposed rule change to (i)
amend Rule G-14 RTRS Procedures under MSRB Rule G-14, on reports of
sales or purchases, to rescind a previously approved but not yet
effective shortening of the amount of time within which brokers,
dealers and municipal securities dealers (``dealers'') must report most
transactions to the MSRB, reverting such timeframe to the currently
effective 15-minute reporting timeframe, (ii) amend the
Rule G-14 RTRS Procedures to eliminate two previously approved but
not yet effective reporting exceptions and a manual trade indicator
relating to the rescinded shortened timeframes, and (iii) make a
related conforming amendment to MSRB Rule G-12, on uniform practice
(``Rule G-12''), as described herein (the ``proposed rule change'').
The provisions that would be rescinded by the proposed rule change
were previously approved by the Commission on September 20, 2024 as
part of a broader set of amendments which have not yet become effective
(the ``2024 Amendments'').\3\ A portion of the 2024 Amendments would
not be modified by this proposed rule change, as described below. If
the Commission approves the proposed rule change, the MSRB will
announce the effective date of the proposed rule change in a regulatory
notice to be published on the MSRB website. The effective date(s) of
the portions of the 2024 Amendments not modified by this proposed rule
change will also be announced in such regulatory notice.
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\3\ See Exchange Act Release No. 101118 (Sept. 20, 2024), 89 FR
78955 (Sept. 26, 2024), File No. SR-MSRB-2024-01 (the ``2024
Approval Order''). The MSRB has not announced the effective date of
the 2024 Amendments. The text of the approved but not yet effective
2024 Amendments is set forth in Exhibit 5 of Amendment No. 1 of File
No. SR-MSRB-2024-01, available at https://www.msrb.org/sites/default/files/2024-07/MSRB-2024-01-A-1.pdf. See also MSRB Notice
2024-12 (SEC Approves Amendments to MSRB Rule G-14 to Shorten
Timeframe for Reporting Transactions in Municipal Securities) (Sept.
20, 2024) (the ``2024 MSRB Notice''). Unless otherwise specifically
noted, references to rule text are to the text as amended by the
2024 Amendments.
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The text of the proposed rule change is available on the MSRB's
website at https://msrb.org/2025-SEC-Filings, at the MSRB's principal
office, and at the Commission's Public Reference Room.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, the MSRB included statements
concerning the purpose of and basis for the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. The MSRB has prepared summaries, set forth in Sections
A, B, and C below, of the most significant aspects of such statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
Background
Dealers currently are required to report their transactions to the
MSRB's Real-Time Transaction Reporting System (``RTRS'') within 15
minutes of the Time of Trade,\4\ absent an exception,\5\ in accordance
with Rule G-14, the Rule G-14 RTRS Procedures, and the RTRS Users
Manual.\6\ On September 20, 2024, the Commission approved the 2024
Amendments, which modified, among other things, the baseline 15-minute
reporting requirement for reporting trades to RTRS in two ways: (i)
reducing the deadline for reporting such trades to no later than one
minute after the Time of Trade (the ``one-minute reporting
requirement'') and (ii) requiring that trades be reported as soon as
practicable, regardless of the amended deadline (the ``as soon as
practicable requirement''). The 2024 Amendments added two new
exceptions to the new one-minute reporting requirement for trades with
a manual component \7\ and for trades by dealers with limited trading
activity.\8\ The 2024 Amendments also included a requirement that
dealers append a new manual trade indicator to identify all manual
trades.\9\ As noted above, these provisions, while adopted by the MSRB
and approved by the Commission, have not gone into effect.
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\4\ Rule G-14 RTRS Procedures paragraph (d)(iii) defines ``Time
of Trade'' as the time at which a contract is formed for a sale or
purchase of municipal securities at a set quantity and set price.
\5\ Transactions in securities without CUSIP numbers,
transactions in municipal fund securities, and certain inter-dealer
securities movements not eligible for comparison through a clearing
agency are currently exempt from the reporting requirements under
Rule G-14(b)(v). Other transactions, while subject to the reporting
requirements of Rule G-14, currently have certain exceptions from
the baseline 15-minute timeframe as described in Rule G-14 RTRS
Procedures paragraph (a)(ii).
\6\ The RTRS Users Manual is available at https://www.msrb.org/RTRS-Users-Manual.
\7\ The 2024 Amendments added a definition of a trade with a
manual component in paragraph (d)(xii) of Rule G-14 RTRS Procedures,
an exception from the one-minute reporting timeframe for trades with
a manual component in paragraph (a)(ii)(C)(2) of Rule G-14 RTRS
Procedures, and requirements with respect to the timing and related
matters for such reporting in Supplementary Material .02 of Rule G-
14.
\8\ The 2024 Amendments added a definition of a dealer with
limited trading activity in paragraph (d)(xi) of Rule G-14 RTRS
Procedures, an exception from the one-minute reporting timeframe for
trades by a dealer with limited trading activity in paragraph
(a)(ii)(C)(1) of Rule G-14 RTRS Procedures, and requirements with
respect to the timing and related matters for such reporting in
Supplementary Material .01 of Rule G-14.
\9\ The 2024 Amendments added a requirement in paragraph
(b)(iv)(B)(4) of Rule G-14 RTRS Procedures that dealers report any
trade with a manual component with a new special condition
indicator.
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Following the approval of the 2024 Amendments, the MSRB continued
to engage with market participants and received further feedback
expressing various concerns regarding aspects of the one-minute
reporting requirement. These concerns emerged as dealers began
considering the specific steps they would need to undertake to come
into compliance with the 2024 Amendments that related both to
additional scenarios involving potential trades with a manual component
beyond those discussed in the 2024 Amendments, and to issues that could
arise in the case of certain fully automated trades. Some of these
scenarios raised the prospect that a potentially broader array of
circumstances than previously anticipated during the course of the
rulemaking for the 2024 Amendments may exist where, at this time, the
adjustment of dealer systems and workflows, including those dependent
on third party vendors or market utilities, associated with achieving
and complying with the shortened reporting timeframes under the 2024
Amendments might not be feasible in the near-term.
In reviewing trade reporting data through the end of 2024 that
reflected market practices since the 2022 trade reporting data used in
connection with the 2024 Amendments, the MSRB has observed that trades
that were likely reported electronically were being reported more
rapidly in 2024 as
[[Page 26392]]
compared to 2022.\10\ The MSRB previously noted that, to the extent
dealers are not already reporting trades as soon as practicable, the
inclusion of the requirement for reporting as soon as practicable would
have the effect of increasing the proportion of trades being reported
within shorter timeframes than they currently are, without regard to a
one-minute, five-minute or 15-minute deadline, potentially translating
into significant improvement in market-wide average reporting times and
in turn reduce market-wide lags in pricing information being made more
widely available and reduce information arbitrage.\11\ The MSRB
believes, as noted by at least one commenter on the 2024 Amendments,
that the inclusion of the as soon as practicable requirement may, by
itself, result in improvements in the timing of trade reporting, with
the greatest improvements likely to occur for those trades currently
being reported nearer to the 15-minute deadline.\12\
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\10\ See infra Self-Regulatory Organization's Statement on
Burden on Competition--Benefits, Costs, and Effect on Competition--
Trade Reporting Analysis, Table 2 and accompanying text.
\11\ See letter from Ernesto A. Lanza, Chief Regulatory and
Policy Officer, MSRB, to Vanessa Countryman, Secretary, Commission,
dated July 18, 2024, at 17-18, available at https://www.msrb.org/sites/default/files/2024-07/Response-to-Comments-SR-MSRB-2024-01.pdf.
\12\ See, e.g., letter to Ronald W. Smith, MSRB, and Jennifer
Piorko Mitchell, Financial Industry Regulatory Authority
(``FINRA''), from Kenneth E. Bentsen, Jr., President and CEO,
Securities Industry and Financial Markets Association (``SIFMA''),
dated October 3, 2022, at 7 (``SIFMA believes that adding a
requirement to Rule G-14 that reports be made as soon as
practicable, and the SROs providing guidance to broker-dealers on
how they might best make improvements to their reporting practices
in a practicable manner, would materially improve the timing of such
trade reports without having to impose a radical one-minute
mandate.'').
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The MSRB believes that the 2024 Amendments, as modified by the
proposed rule change, would serve to continue to enhance market
transparency without the potential compliance burdens and costs
associated with the one-minute reporting requirement and the use of a
special condition indicator for trades with a manual component. The
MSRB intends to continue monitoring for further improvements in trade
reporting timing and to publish its findings for market participants
and the general public.
As a result, the MSRB has determined that it is appropriate at this
time to rescind the one-minute reporting requirement and related
provisions of the 2024 Amendments and revert the rule language to
maintain the currently-effective 15-minute RTRS reporting standard. The
MSRB has also determined to retain the as soon as practicable
requirement and related provisions, as well as certain other clarifying
amendments, of the 2024 Amendments. The proposed rule change, and the
retained provisions of the 2024 Amendments, are described below.
Proposed Rule Change
The proposed rule change would rescind certain provisions adopted
in the 2024 Amendments. Specifically, the proposed rule change would:
Revert the one-minute deadline for reporting trades to the
existing 15-minute timeframe, so that all types of trades required to
be reported within 15 minutes under the rule language prior to the 2024
Amendments would continue to be subject to the 15-minute reporting
requirement under paragraph (a)(ii) of Rule G-14 RTRS Procedures; \13\
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\13\ The proposed rule change would also partially revert the
change made by the 2024 Amendments to Rule G-12(f)(i), relating to
the timing for submission of trades to be compared, to reflect the
reversion from one minute to 15 minutes under the proposed rule
change.
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Eliminate the two new intra-day exceptions for dealers
with limited trading activity and trades with a manual component by
deleting paragraph (a)(ii)(C) of Rule G-14 RTRS Procedures and
Supplementary Material .01 and .02 of Rule G-14, as well as deleting
the definitions of dealer with limited trading activity in paragraph
(d)(xi) of Rule G-14 RTRS Procedures and trade with a manual component
in paragraph (d)(xii) of Rule G-14 RTRS Procedures, as such exceptions
and related provisions are no longer relevant due to the rescinding of
the one-minute reporting requirement; and
Eliminate the new special condition indicator requirement
for trades with a manual component by deleting paragraph (b)(iv)(B)(4)
of Rule G-14 RTRS Procedures, as under the reverted rule there is no
necessity for distinguishing between trades with a manual component and
other trades.\14\
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\14\ Paragraphs (b)(iv)(B)(5)-(7) would be renumbered to reflect
this deletion.
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In addition to the changes described above, the 2024 Amendments
included certain changes that would, as a matter of substance, be
retained and not be affected by this proposed rule change except with
respect to certain non-substantive changes described below. The
addition by the 2024 Amendments to paragraph (a)(ii) of Rule G-14 RTRS
Procedures of the requirement that transactions effected with a Time of
Trade during the hours of the RTRS Business Day must be reported as
soon as practicable would be retained without change.\15\ In addition,
Supplementary Material .03 added by the 2024 Amendments would be
retained and renumbered as Supplementary Material .01, with minor non-
substantive grammatical and clarifying changes.\16\ During the
rulemaking process in connection with the 2024 Amendments, the MSRB
received general industry support for inclusion of these
provisions,\17\ which harmonize the Rule G-14 RTRS Procedures with
FINRA Rule 6730(a) and Supplementary Material .03 thereof in connection
with Trade Reporting and Compliance Engine (``TRACE'') requirements for
reporting TRACE-eligible securities. Retention of the as soon as
practicable requirement in particular constitutes a key component of
the basis for reverting the one-minute reporting requirement pursuant
to this proposed rule change, as the MSRB believes that the as soon as
practicable requirement would strengthen the existing trend since 2022
of faster trade reporting in a manner that minimizes the burden on
dealers.\18\
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\15\ See Exchange Act Release No. 99402 (Jan. 19, 2024), 89 FR
5384, 5386 (Jan. 26, 2024), File No. SR-MSRB-2024-01 (the ``2024
Filing Notice''), at Section II.A.1, discussion under heading New
Requirement To Report Trades ``as Soon as Practicable,'' for a full
discussion of these provisions. See also 2024 MSRB Notice, Section
B. New Requirement to Report Trades as Soon as Practicable, at 3-4.
While the proposed rule change would revert a portion of the changes
made by the 2024 Amendments to Rule G-12(f)(i) to reflect the
reversion of the one-minute reporting timeframe back to 15 minutes,
as described in supra note 13, the portion of such changes to Rule
G-12(f)(i) reflecting the addition of the ``as soon as practicable''
language would be retained so that such trades must be submitted for
comparison as soon as practicable. Another minor language change
made to Information Facility 1 by the 2024 Amendments would also be
retained without change.
\16\ The word ``reporting'' would be added to the phrase
``trades with a manual reporting component'' to provide greater
clarity in light of the deletion of the substantive provisions and
definition relating to the exception for trades with a manual
component.
\17\ See 2024 Filing Notice, 89 FR at 5403, Section II.C,
discussion under heading As Soon as Practicable Requirement. See
also letters to Vanessa A. Countryman, Secretary, Commission, from:
Michael Decker, Senior Vice President, Bond Dealers of America,
dated August 21, 2024, at 3; Melissa P. Hoots, Chief Executive
Officer and Chief Operating Officer, Falcon Square Capital, LLC,
dated August 21, 2024, at 4; and Matt Dalton, Chief Executive
Officer, Belle Haven Investments, LP, dated August 21, 2024, at 5.
\18\ See infra Self-Regulatory Organization's Statement on
Burden on Competition--Benefits, Costs, and Effect on Competition--
Benefits.
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Another change included in the 2024 Amendments that would not be
affected by this proposed rule change and would be retained consists of
language added to paragraph (a)(iv) of Rule G-14 RTRS Procedures
regarding designation of late
[[Page 26393]]
trades and patterns or practices of late reporting without exceptional
circumstances or reasonable justification.\19\ In line with these
provisions, the MSRB expects that the regulatory authorities that
examine dealers and enforce compliance with the reporting timeframes
established under Rule G-14 RTRS Procedures will focus their
examination for and enforcement of the rule's timing requirements on
the consistency of timely reporting and the existence of effective
controls to limit late reporting to exceptional circumstances or where
reasonable justification exists for a late trade report, rather than on
individual late trade report outliers. Notwithstanding such
expectation, where facts and circumstances indicate that an individual
late report was intentional or otherwise egregious, or could reasonably
be viewed as potentially giving rise to an associated fair practice,
fair pricing, best execution or other material regulatory concern under
MSRB or Commission rules with respect to that or a related transaction,
the regulatory authorities could reasonably determine to take action
with respect to such late trade in the examination or enforcement
context.\20\
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\19\ See 2024 Filing Notice, 89 FR at 5391, Section II.A.1,
discussion under heading Pattern or Practice of Late Trade
Reporting, for a full discussion of these provisions. See also 2024
MSRB Notice, Section F. Pattern or Practice of Late Trade Reporting;
Exceptional Circumstances or Reasonable Justification, at 18-20.
\20\ Dealers that seek to document system outages that might
factor into whether exceptional circumstances or reasonable
justification may exist for a late trade report can use the MSRB's
Dealer System Outage Report process in MSRB Gateway to document
system outages or other technology-related problems that affect
their ability to comply with MSRB rules. Such reports are provided
to authorities charged with enforcing MSRB rules.
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Additional clarifying amendments from the 2024 Amendments that
reorganize certain existing materials into more logical groupings, such
as previously established special condition indicators, and clarifying
the reporting timeframe for trades on an invalid RTTM trade date, would
also be retained.\21\
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\21\ See 2024 Filing Notice, 89 FR at 5392, Section II.A.1,
discussion under heading Technical Amendments, for a full discussion
of these provisions.
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2. Statutory Basis
Section 15B(b)(2) of the Exchange Act \22\ provides that the MSRB
shall propose and adopt rules to effect the purposes of the Exchange
Act with respect to, among other matters, transactions in municipal
securities effected by dealers. Section 15B(b)(2)(C) of the Exchange
Act \23\ further provides, among other things, that the MSRB's rules
shall be designed to prevent fraudulent and manipulative acts and
practices, to promote just and equitable principles of trade, to foster
cooperation and coordination with persons engaged in regulating,
clearing, settling, processing information with respect to, and
facilitating transactions in municipal securities and municipal
financial products, to remove impediments to and perfect the mechanism
of a free and open market in municipal securities and municipal
financial products, and, in general, to protect investors, municipal
entities, obligated persons, and the public interest.
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\22\ 15 U.S.C. 78o-4(b)(2).
\23\ 15 U.S.C. 78o-4(b)(2)(C).
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The MSRB believes the proposed rule change is consistent with
Section 15B(b)(2)(C) of the Exchange Act \24\ because it would promote
just and equitable principles of trade, foster cooperation and
coordination with personnel engaged in regulating and facilitating
transactions in municipal securities, remove impediments to a free and
open market in municipal securities and generally protect investors and
the public interest. As discussed above, the MSRB believes that the
proposed rule change is appropriate at this time, given the additional
information obtained since the approval of the 2024 Amendments. The
additional information suggests that both the burdens of the shortened
reporting timeframe (together with the associated exceptions and manual
trade flag) in the 2024 Amendments may be higher than initially
estimated and the net positive impact of the tightened timeframe, as
compared to not changing the timeframe, may not be as large as
originally estimated in light of observed improvements in actual
reporting performance by dealers between 2022 and 2024 under the
current 15-minute standard. The proposed rule change represents a
responsive adjustment to the 2024 Amendments to address market
participants' feasibility and compliance concerns that could have
impeded the achievement of the expected benefits thereof.
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\24\ Id.
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The proposed rule change is intended to alleviate compliance
challenges and avoid potential unintended consequences--particularly
given the broad prevalence of manual and hybrid trading workflows for
municipal securities. Therefore, the MSRB believes the proposed rule
change would help achieve the purposes of the Exchange Act to remove
impediments to and perfect the mechanism of a free and open market in
municipal securities and to protect investors by enhancing and
facilitating dealer compliance without imposing undue costs and burdens
that are not necessary or appropriate at this time, thereby making it
more likely that the goal of greater transparency for market
participants would occur in a more cost-efficient manner. The MSRB
believes that the proposed rule change would continue to promote the
reduction in information asymmetry between market professionals and
retail investors sought by the 2024 Amendments through the retention of
the as soon as practicable requirement without creating the additional
process burdens resulting from the classification and flagging of
trades as having or not having a manual trade component or being
effected by dealers with differing levels of trade activity, which had
the potential to create different treatment by dealers for trades
fitting one or another of such categories.
The MSRB further believes that the proposed rule change would
remove impediments to and enhance the operation of a free and open
market in municipal securities by enabling dealers to better comply
with applicable reporting timeframes by promoting further enhancements
to participants' systems and processes for reporting trades in a manner
best suited to their respective business models. Thus, under the as
soon as practicable requirement, dealers would be able to make
appropriate enhancements consistent with their own business practices
without needing to adapt their systems and processes to the heightened
complexities of, and without the imposition of the added costs
associated with, a significantly shortened reporting timeframe and
associated provisions that would be rescinded by the proposed rule
change.
The proposed rule change would promote just and equitable
principles of trade because it would reduce information asymmetry
between market professionals (such as dealers and institutional
investors) and retail investors by ensuring increased access to more
timely information about executed municipal securities transactions for
all investors. Currently, market professionals may in some
circumstances have better or more rapid access to information about
trade prices through market venues to which retail investors do not
have access, and the reduction in the timeframe for trade reporting
would shorten or eliminate the period during which any such asymmetry
in access to such information may exist.
[[Page 26394]]
The proposed rule change would foster cooperation and coordination
with persons engaged in regulating and processing information,
facilitating a consistent standard for trade reporting across many
fixed income products, including municipal securities. The 2024
Amendments were developed in close coordination with FINRA, which
adopted a similar shortened trade reporting requirement for many TRACE-
eligible securities, and the MSRB and FINRA continue to work in
coordination on issues that have presented since such adoption.\25\
Fostering a consistent approach across classes of securities would
facilitate greater and more efficient compliance among MSRB-registered
dealers, the majority of which also transact in other fixed income
securities that are subject to FINRA's regulatory authority. Consistent
trade reporting requirements tend to reduce the risk of potential
confusion and may reduce compliance burdens resulting from inconsistent
obligations and standards for different classes of securities. The
proposed rule change would continue to promote regulatory consistency,
reducing potential errors caused by market participants' imperfect
application of differing standards when executing and reporting
transactions in municipal securities.
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\25\ See FINRA, Updating TRACE Reporting Timeframes (Feb. 5,
2025), available at https://www.finra.org/media-center/blog/updating-trace-reporting-timeframes; MSRB, MSRB Board Authorizes
Further Amendments to Rule G-14, Withdraws Pre-Trade Concept Release
(Mar. 7, 2025), available at https://www.msrb.org/Press-Releases/MSRB-Board-Authorizes-Further-Amendments-Rule-G-14-Withdraws-Pre-Trade-Concept.
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Therefore, the MSRB believes that the proposed rule change
satisfies the applicable requirements of Section 15B(b)(2)(C) of the
Exchange Act.\26\
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\26\ 15 U.S.C. 78o-4(b)(2)(C).
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B. Self-Regulatory Organization's Statement on Burden on Competition
Section 15B(b)(2)(C) of the Exchange Act requires that MSRB rules
not be designed to impose any burden on competition not necessary or
appropriate in furtherance of the purposes of the Exchange Act.\27\ The
proposed rule change would (i) eliminate the reduction in timeframe
within which dealers must report trades to RTRS previously adopted by
the MSRB but not yet made effective, (ii) eliminate two previously
approved but not yet effective reporting exceptions and a manual trade
indicator, and (iii) make a conforming amendment to Rule G-12. The MSRB
believes the proposed rule change would not impose any burden on
competition, as the proposed rule change would likely further
accelerate the trade reporting process without adding significant costs
to dealers and would be applicable to all dealers equally. Therefore,
the MSRB does not believe the proposed rule change would result in any
burden on competition that is not necessary or appropriate in
furtherance of the purposes of the Exchange Act.
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\27\ Id.
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In making this determination, MSRB staff was guided by the MSRB's
Policy on the Use of Economic Analysis in MSRB Rulemaking.\28\ In
accordance with this policy, the MSRB evaluated the potential impacts
on competition of not only the provisions of the proposed rule change
but also of the retained provisions of the 2024 Amendments intended to
encourage dealers to further accelerate the trade reporting process.
The one-minute reporting requirement, which would be amended by the
proposed rule change, and the as soon as practicable requirement, which
would be retained, were distinct but overlapping provisions of the 2024
Amendments both of which were designed to achieve more timely reporting
of trades. While the one-minute reporting requirement represented a
prescriptive approach to this goal, the as soon as practicable
requirement represented a principles-based approach that would serve to
enhance post-trade market transparency, particularly for individual
(retail) investors, without the additional compliance burdens
associated with a significantly shortened reporting timeframe for
dealers. Historically, when compared to other securities markets, the
municipal securities market has been considered to trade less
frequently, with only about one percent of all municipal securities
trading on a given trading day. In addition, pre-trade quotes are not
widely available to all investors, especially retail investors who may
not purchase vendor pricing tools and may be more reliant on post trade
data.\29\ Therefore, post trade data is important information available
to these investors, and the reporting of more contemporaneous
transactions sooner would benefit investors for the relevant security
as well as other comparable securities. In addition, analogous trade
reporting rules for other fixed income securities markets already
contain the as soon as practicable requirement; \30\ consequently, the
proposed rule change is also intended to make trade reporting
requirements for municipal securities consistent with analogous
reporting requirements for other fixed income securities.\31\
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\28\ The Policy on the Use of Economic Analysis in MSRB
Rulemaking is available at https://www.msrb.org/Policy-Use-Economic-Analysis-MSRB-Rulemaking. In evaluating whether there was a burden
on competition, the MSRB was guided by its principles that require
the MSRB to consider costs and benefits of a rule change, its impact
on capital formation and the main reasonable alternative regulatory
approaches.
\29\ See Wu, Simon Z., John Bagley and Marcelo Vieira,
``Analysis of Municipal Securities Pre-Trade Data from Alternative
Trading Systems,'' Research Paper, Municipal Securities Rulemaking
Board, October 2018; Government Accountability Office (``GAO''),
``Municipal Securities: Overview of Market Structure, Pricing, and
Regulation,'' Report to Congressional Committees, January 2012, at
p. 6; Green, Richard C., Burton Hollifield, and Norman
Sch[uuml]rhoff. ``Financial intermediation and the costs of trading
in an opaque market.'' The Review of Financial Studies 20.2 (2007),
at pp. 275-314.
\30\ FINRA Rule 6730(a) states that ``[a] member must report a
transaction in a TRACE-Eligible Security as soon as practicable, but
no later than within 15 minutes of the Time of Execution, except as
otherwise specifically provided below.''
\31\ See supra note 25 and accompanying text.
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Relevant Baselines
The MSRB's Policy on the Use of Economic Analysis outlines that
rulemaking will articulate a baseline against which to measure the
likely economic impact of the proposed rule change,\32\ which is
essential in considering the likely costs and benefits of a proposed
rule change when the proposal is fully implemented (future state).
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\32\ See supra note 28. The policy identifies the baseline as
``an assessment of the status of the markets and participants
potentially affected directly or indirectly by a proposed rule
change (collectively, the ``affected parties'') in the absence of
the proposed rule change being implemented.''
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[[Page 26395]]
For this proposed rule change, the baseline is Rule G-14 RTRS
Procedures (a)(ii) currently in effect that require transactions to be
reported within 15 minutes after the Time of Trade with limited
exceptions, but does not require that trades be reported as soon as
practicable. This is because the 2024 Amendments, while approved by the
SEC, have not yet gone into effect and therefore have never been
implemented. In fact, the MSRB has never established an effective date
for the 2024 Amendments, so presumably dealers are still abiding by the
current practice, with no effective date expected to become effective
in the foreseeable future.\33\ Therefore, the future state for this
analysis would consist of the proposed rule change maintaining the
currently-effective 15-minute reporting requirement while retaining and
implementing the as soon as practicable requirement of the 2024
Amendments, as a comparison to the current baseline state without the
as soon as practicable requirement.
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\33\ The MSRB had previously suggested that it would provide an
extended effective date for the one-minute reporting requirement,
with further extended periods for effectiveness for trades with a
manual component, due to the complexity of the one-minute reporting
requirement and the related exceptions and trade flagging
requirements. See 2024 Filing Notice, 89 FR at 5392, at Section
II.A.1, discussion under heading Effective Date and Implementation.
---------------------------------------------------------------------------
Separately, the MSRB is also assessing the impact of implementing
all of the requirements of the 2024 Amendments as a comparison to the
current proposed rule change as one of the regulatory alternatives
(Alternative 1) in the section below. The 2024 Amendments, if they were
to become effective, would shorten the reporting timeframe for most
transactions from 15 minutes to one minute after the time of trade,
would require dealers to report certain transactions with a new trade
indicator, would introduce two new intra-day exceptions to the one-
minute reporting requirement and would require that trades be reported
as soon as practicable.
Benefits, Costs, and Effect on Competition
Trade Reporting Analysis
The MSRB's updated analysis shows that most trades are indeed
reported much sooner than the currently operative 15-minute trade
reporting deadline in 2024,\34\ potentially due at least in part to the
advancement in technology. Specifically, as illustrated in Table 1
below, in 2024, out of all reportable municipal securities trades
required to be reported within 15 minutes that are not subject to
another end of day reporting exception or a post-trade day reporting
exception,\35\ approximately 80.8 percent of trades were already
reported within one minute after the Time of Trade.\36\ In addition,
approximately 17.3 percent of trades were reported between one minute
and five minutes after the Time of Trade, for a combined total of 98.1
percent that were reported within five minutes. Therefore, most trades
already satisfy a shorter than 15-minute reporting requirement. In
addition, the MSRB observed a noticeable difference in the speed of
trade reporting by different trade size groups, with the reporting time
increasing with trade size. While 82.6 percent of trades with trade
size of $100,000 par value or less (approximately 83.7 percent of all
trades) were reported within one minute in 2024, only 42.8 percent of
trades with trade size between $1,000,000 and $5,000,000 par value and
28.8 percent of trades with trade size above $5,000,000 par value were
reported within one minute. A possible explanation is that larger
institutional-sized trades are more likely to be executed via non-
electronic means and may rely upon more manual processing steps.\37\ On
the other hand, smaller-sized trades are more likely to be executed and
processed electronically, which could facilitate faster trade
reporting.
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\34\ In 2024, while the speed of trade reporting increased, RTRS
also had the highest number of trades on record since its
implementation in 2005, although the amount of par value traded was
not a record high.
\35\ See Rule G-14 RTRS Procedures paragraphs (a)(ii)(A) and (B)
(as such provisions were redesignated by the 2024 Amendments) for
end of trade day reporting exceptions and post-trade day reporting
exceptions.
\36\ The analysis in this rule filing only includes trades
reportable within 15 minutes by dealers and excludes trades that are
exempt from the current 15-minute reporting time including, for
example, trades flagged as being executed at the List Offering or
Takedown Transactions, trades in short-term instruments maturing in
nine months or less, Auction Rate Securities, Variable Rate Demand
Obligations, trades in commercial paper, as well as trades ``away
from market,'' among other exceptions. See Rule G-14 RTRS Procedures
paragraphs (a)(ii)(A) and (B) (as such provisions were redesignated
by the 2024 Amendments). For purposes of the analysis in this
section, if an initially reported trade was corrected later, the
later timestamp was used for calculating the trade reporting time
more conservatively. All figures are approximate.
\37\ MSRB staff conducted oral interviews with dealers and data
providers in the fall of 2022 and the winter and spring of 2023 and
was informed that larger institutional-sized trades are more likely
to be executed via negotiations and involve manual processes.
Table 1--Trade Report Time by Trade Size--Cumulative Percentages
[January 2024 to December 2024]
--------------------------------------------------------------------------------------------------------------------------------------------------------
All eligible $100,000 or >$100,000- >=$1,000,000- >$5,000,000
Difference between execution and reported time trades (%) less (%) $999,999 (%) $5,000,000 (%) (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
15 Seconds................................................... 34.2 35.7 28.5 13.1 7.8
30 Seconds................................................... 56.7 58.6 49.7 24.9 15.3
1 Minute..................................................... 80.8 82.6 74.4 42.8 28.8
2 Minutes.................................................... 93.4 94.7 89.1 67.4 54.0
3 Minutes.................................................... 96.5 97.3 93.9 79.8 70.1
5 Minutes.................................................... 98.1 98.5 96.7 89.4 84.4
10 Minutes................................................... 99.2 99.4 98.6 96.1 94.1
15 Minutes................................................... 99.5 99.6 99.1 97.7 96.1
30 Minutes................................................... 99.7 99.8 99.4 98.8 97.7
1 Hour....................................................... 99.9 99.9 99.8 99.6 99.4
>1 Hour...................................................... 100.0 100.0 100.0 100.0 100.0
.............. .............. ................. ...................... ..............
Share of Eligible Trades..................................... 100.0 83.7 14.7 1.4 0.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 26396]]
In addition, the MSRB observed noticeable decreases in the time it
took to report trades in 2024 compared to 2022, where approximately
78.1 percent were reported within one minute in 2022 and a combined
total of 97.9 percent were reported within five minutes, compared to
80.8 percent reported within one minute in 2024 and 98.1 percent within
five minutes (Table 2). The MSRB is also encouraged to observe that the
improvements in timely trade reporting were even more significant for
trades reporting within 15 seconds and 30 seconds, from 24.8% in 2022
to 34.2% in 2024 for 15 seconds, and from 52.7% in 2022 to 56.7% in
2024 for 30 seconds (see Table 2).
Table 2--Trade Report Time Comparison: 2022 and 2024
------------------------------------------------------------------------
Difference between execution and
reported time 2022 data (%) 2024 data (%)
------------------------------------------------------------------------
15 Seconds.............................. 24.8 34.2
30 Seconds.............................. 52.7 56.7
1 Minute................................ 78.1 80.8
5 Minutes............................... 97.9 98.1
10 Minutes.............................. 99.3 99.2
15 Minutes.............................. 99.6 99.5
------------------------------------------------------------------------
Benefits
The primary benefit of retaining and implementing the as soon as
practicable requirement is that it would encourage dealers to continue
to reduce trade reporting times due to the provision's obligation and
thereby increase overall price transparency. Between 2022 and 2024, the
municipal securities market not only experienced greater trading
activity but also faster trade reporting, especially for the number of
trades reported within one minute. The MSRB believes the proposed rule
change may further accelerate trade reporting, particularly for some
trades that are currently being reported closer to the 15-minute
deadline. Hence, by retaining and implementing the as soon as
practicable requirement, the MSRB believes investors could benefit from
enhanced price transparency because of potentially faster trade
reporting.
With limited trading volume on a particular day, municipal
securities information on trades in the same security as well as in
other comparable municipal securities would both be valuable in pricing
a security.\38\ Furthermore, with far fewer trades in municipal
securities when compared to treasury and corporate bonds, the MSRB also
expects that each additional timely data point from post trade
reporting in municipal securities would potentially be more valuable to
investors and other market participants than a data point from these
other markets. In addition to investors, issuers, underwriters and
other market participants such as data vendors would also experience
some additional benefit from faster data transmission. Finally,
retaining and aligning the as soon as practicable requirement for
municipal securities with other fixed income securities would reduce
any confusion for dealers who trade all these fixed-income securities,
bringing regulatory consistency across fixed-income markets.\39\
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\38\ See GAO, ``Municipal Securities: Overview of Market
Structure, Pricing, and Regulation,'' Report to Congressional
Committees, January 2012, at p. 12 (``Broker-dealers we spoke with
said that the price of a recently reported interdealer trade for a
security was a particularly good indication of its value for that
segment of the market. However, if a security has not traded
recently, they said they instead look for recent trades in
comparable securities.'').
\39\ A few of the commenters who responded to the original
request for comment mentioned that many dealers are already adhering
to the ``as soon as practicable'' language as it is already part of
FINRA rules on trade reporting. See supra note 17.
---------------------------------------------------------------------------
Given the improvement in trade reporting time between 2022 and
2024, the MSRB is planning to continue analyzing trade data and
monitoring for reporting patterns that emerge with respect to timing of
reporting.
Costs
The MSRB acknowledges that dealers would likely incur minor
additional costs, relative to the current state, to implement changes
from the proposed rule change along with the retained portions of the
2024 Amendments. These additional costs would likely include one time
or upfront costs (e.g., setting up and/or revising policies and
procedures, education and training), and ongoing compliance costs to
ensure changes from the proposed rule change are followed. Firms that
also trade other fixed-income securities in addition to municipal
securities, and therefore are already subject to the as soon as
practicable standard for other fixed income products, may experience
lower costs to implement this aspect of the retained 2024 Amendments
than the MSRB's estimates because those firms can adapt their existing
compliance program for municipal securities.
Upfront Costs
The MSRB expects that dealers would expend resources to implement a
thoughtful supervisory and compliance regime in order to satisfy the as
soon as practicable requirement of the retained portions of the 2024
Amendments. It is possible that dealers may need to seek appropriate
advice from in-house and/or outside legal and compliance professionals
to revise policies and procedures in compliance with the proposed rule
change. The MSRB anticipates firms would devote approximately 11 hours
to developing new policies and procedures to address the as soon as
practicable requirement. This process is estimated to cost each dealer
$5,068.\40\ Additionally, before the proposed rule change and the
retained portions of the 2024 Amendments become effective, the MSRB
expects that a compliance professional would devote time to training
and educating registered representatives and others to ensure
compliance with the as soon as practicable requirement. The total cost
of training and education is estimated to be $1,179. The MSRB therefore
estimates the total upfront costs to be $6,246 (see Table 3).
---------------------------------------------------------------------------
\40\ The hourly rate data was gathered from the Commission's
Amendments to Exchange Act Rule 3b-16. See Exchange Act Release No.
94062 (Sep. 20, 2022), 17 CFR parts 232, 240, 242, 249 (Jan. 26,
2022) (File No. S7-02-22), p. 477 n. 1102 (citing the original
source of the data from SIFMA Management & Professional Earnings in
the Securities Industry 2013). The data reflects the 2024 hourly
rate level after adjusting for the annual wage inflation between
2013 and 2024, using the Federal Reserve Bank of St. Louis
Employment Cost Index: Wages and Salaries Private Industry,
available at: https://fred.stlouisfed.org/series/ECIWAG. The MSRB
uses a blended hourly rate of $286 for a Registered Representative,
$379 for a Compliance Manager, $448 for an In-House Compliance
Attorney, $497 for Outside Legal Counsel, $589 for a Director of
Compliance and $670 for the Chief Compliance Officer, and estimates
a total of 17 hours for dealers to update policies.
[[Page 26397]]
Table 3--Estimated Upfront Costs for Each Dealer \41\
----------------------------------------------------------------------------------------------------------------
Number of
Cost components Hourly rate hours Cost per firm
----------------------------------------------------------------------------------------------------------------
Upfront Costs: .............. .............. ..............
(a) Revision of Policies and Procedures: .............. .............. ..............
Registered Representative................................... $286 2 $571
Compliance Manager.......................................... 379 2 759
In-House Compliance Counsel................................. 448 2 895
Outside Legal Counsel....................................... 497 2 994
Director of Compliance...................................... 589 2 1,179
Chief Compliance Officer (CCO).............................. 670 1 670
Subtotal................................................ .............. .............. 5,068
(b) Training and Education .............. .............. ..............
Director of Compliance...................................... 589 2 1,179
Subtotal................................................ .............. .............. 1,179
-----------------------------------------------
Total Upfront Costs................................. .............. .............. 6,246
----------------------------------------------------------------------------------------------------------------
Ongoing Compliance Costs
The MSRB anticipates relatively minor annual ongoing costs of
promoting compliance with the as soon as practicable requirement. To do
so, firms would develop compliance training and supervisory procedures
to review trades on a periodic basis. The total cost of compliance
personnel to monitor, review and educate trading desks is estimated to
be $1,179 per year (see Table 4). Comparatively speaking, these ongoing
compliance costs may not significantly exceed the costs in the current
baseline, as the MSRB believes that all dealers should already have
compliance programs in place ensuring fidelity to the current trade
reporting requirement, and the vast majority of dealers that trade
other fixed-income securities in addition to municipal securities can
adapt their existing compliance programs for municipal securities.
---------------------------------------------------------------------------
\41\ Numbers in the table have been rounded to the dollar;
therefore, totals may not exactly match.
Table 4--Estimated Ongoing Annual Training and Education Costs for Each Dealer \42\
----------------------------------------------------------------------------------------------------------------
Number of
Cost components Hourly rate hours Cost per firm
----------------------------------------------------------------------------------------------------------------
Ongoing Annual Costs .............. .............. ..............
(a) Training, Education and Supervisory .............. .............. ..............
Procedures
Director of Compliance...................................... $589 2 $1,179
-----------------------------------------------
.............. .............. 1,179
----------------------------------------------------------------------------------------------------------------
Effect on Competition, Efficiency and Capital Formation
---------------------------------------------------------------------------
\42\ The MSRB estimates a total of two hours per year for
Director of Compliance ($589 per hour) to conduct training,
education and to engage in supervisory activities under their
policies and procedures for each dealer.
---------------------------------------------------------------------------
The MSRB believes the proposed rule change would improve market
efficiency by encouraging the industry's continued movement towards
speedy trade reporting. Investors would likely benefit from a further
reduction in trade reporting time, which would generate additional
benefits for investors from more immediate post-trade transparency and
potentially lower transaction costs. Thus, it is possible that the
proposed rule change would lead to greater investor participation and
further stimulate market activity by encouraging more trading by
existing investors and/or bring in new investors to the municipal
securities market over the long term and contribute to an overall
increase in capital formation. Finally, the harmonization of reporting
requirements for municipal securities with other fixed-income markets
would create consistency for dealers who have trading operations in all
these markets and would thus increase efficiency in terms of their
compliance burdens. Therefore, the MSRB believes that the proposed rule
change would facilitate capital formation.
Dealers may be impacted by the proposed rule change through any
upfront costs of revising policies and procedures and ongoing
compliance costs; however, the broader impact on competition in the
municipal securities market is expected to be minor, as the requirement
applies to all dealers equally. The MSRB acknowledges that smaller
dealers may bear proportionately higher upfront costs than larger
dealers, but the relatively modest upfront costs borne by dealers
overall are necessary to ensure a uniform standard across all dealers
and to bring the municipal securities market in alignment with other
securities markets. Therefore, the MSRB does not believe the ``as soon
as practicable'' requirement would result in any burden on competition
that is not necessary or appropriate in furtherance of the purposes of
the Exchange Act.
Identifying and Evaluating Reasonable Alternative Regulatory Approaches
Alternative 1
The MSRB has considered and evaluated reasonable regulatory
alternatives. One alternative the MSRB analyzed was to fully retain the
2024 Amendments as approved. This alternative would require all trades
reported within one minute after the Time of Trade for active dealers
that report annually, 2,500 trades or more in one of the past two
years, except for manual trades which would be required to follow a
three-year phased-in schedule from 15 minutes to five
[[Page 26398]]
minutes trade reporting. In addition, this alternative would require
all dealers to report certain transactions with a new trade indicator.
Finally, this alternative would also require that trades be reported as
soon as practicable. While this alternative would likely further
accelerate the trade reporting process when compared to the current
state, it would also impose substantial technology subscription or
upgrade expenses for active dealers who are currently not close to
reporting all fully automated trades within one minute,\43\ and
additional compliance and system costs for all dealers to provide a new
trade indicator.
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\43\ See 2024 Approval Order, 89 FR at 78961-62 (discussing the
MSRB's consideration of potential technological costs).
---------------------------------------------------------------------------
Per MSRB's prior estimate, it would be at least $6.8 million total
for the annual ongoing technology subscription costs for the industry
based on the 2022 data, in addition to the estimated $5.2 million for
the upfront costs to revise policy and procedures and to conduct
training and education.\44\ Furthermore, there would be additional
costs for system development to flag manual trades, and to ensure that
manual trades' reporting time to be within five minutes after the Time
of Trade eventually. While the MSRB did not have sufficient data to
provide an estimate on the costs of reporting the trade indicator by
dealers, based on further information received from dealers since
approval of the 2024 Amendments,\45\ defining the manual trades may not
be straightforward, which would further amplify the time and costs to
implement the approved amendments to Rule G-14.\46\
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\44\ See Amendment No. 1 to File No. SR-MSRB-2024-01, Revised
Table 4, p. 15, available at https://www.msrb.org/sites/default/files/2024-07/MSRB-2024-01-A-1.pdf.
\45\ See supra Self-Regulatory Organization's Statement of the
Purpose of, and Statutory Basis for, the Proposed Rule Change--
Purpose--Background.
\46\ See 2024 Approval Order, 89 FR at 78960-62 (summarizing
stakeholder concerns and MSRB considerations of potential costs).
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Therefore, the MSRB believes the proposed rule change is, on
balance, superior to the 2024 Amendments because of the significantly
reduced cost estimate on implementation. While eliminating the one-
minute reporting requirement would likely yield lower transparency
benefits, based on the trend observed with 2024 data, the MSRB is
cautiously optimistic that the industry would continue the trend of
gradually moving towards faster trade reporting by its own volition,
further propelled by the addition of the as soon as practicable
requirement that would be retained from the 2024 Amendments, and
greater electronification. As previously mentioned, the MSRB is
encouraged to see an improvement in the trade reporting times between
2022 and 2024. The number of trades reported within 15 seconds
increased from 24.8% to 34.2% while trades reported within 30 seconds
increased from 52.7% to 56.7% between 2022 and 2024. One possible
explanation for this improvement is the continued electronification of
municipal securities trading, and the MSRB would like to monitor future
progress with the proposed rule change.
Alternative 2
Another alternative the MSRB considered was to rescind the 2024
Amendments entirely, including the as soon as practicable requirement.
Essentially, this alternative would revert Rule G-14 to the currently
operative version which was last amended in 2015. While this
alternative certainly would not impose any additional costs to dealers,
trade reporting requirements for municipal securities would continue to
not align with analogous trade reporting requirements for other fixed
income securities that already contain the as soon as practicable
requirement. The MSRB believes that such an alignment would provide
greater regulatory consistency in the trade reporting and compliance
process, and reduce confusion for dealers that trade both municipal
securities and other fixed income securities. In addition, the proposed
rule change would likely result in a further shortening of trade
reporting time and hence increase market transparency, without imposing
a significant cost on the industry.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
Written comments were neither solicited nor received on the
proposed rule change.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of publication of this notice in the
Federal Register or within such longer period of up to 90 days (i) as
the Commission may designate if it finds such longer period to be
appropriate and publishes its reasons for so finding or (ii) as to
which the self-regulatory organization consents, the Commission will:
(A) by order approve or disapprove such proposed rule change, or
(B) institute proceedings to determine whether the proposed rule
change should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to [email protected]. Please
include File Number SR-MSRB-2025-01 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.
All submissions should refer to File Number SR-MSRB-2025-01. This
file number should be included on the subject line if email is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's internet website (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for website viewing and
printing in the Commission's Public Reference Room, 100 F Street NE,
Washington, DC 20549 on official business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the filing also will be available
for inspection and copying at the principal office of the MSRB. Do not
include personal identifiable information in submissions; you should
submit only information that you wish to make available publicly. We
may redact in part or withhold entirely from publication submitted
material that is obscene or subject to copyright protection. All
submissions should refer to File Number SR-MSRB-2025-01 and should be
submitted on or before July 11, 2025.
[[Page 26399]]
For the Commission, pursuant to delegated authority.\47\
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\47\ 17 CFR 200.30-3(a)(12).
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Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2025-11292 Filed 6-18-25; 8:45 am]
BILLING CODE 8011-01-P