The MSRB provided guidance to member firms on amendments to MSRB Rule G-14 that became effective on July 18, 2016. The amendments require broker-dealers and municipal securities dealers to report all executed transactions in most municipal securities to the MSRB's Real-Time Transaction Reporting System within 15 minutes of the time of trade (subject to certain exceptions). The guidance includes a substantive FAQ.
The guidance addresses the following questions, among others:
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What is the "time of trade?"
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What is the "time of trade" for new issue securities?
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Is the non-transaction-based compensation special condition indicator ("NTBC indicator") used only on customer transactions executed in wrap fee accounts?
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Is the NTBC indicator used only for customer trades executed on a principal basis?
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Is the NTBC indicator used only for retail customer accounts?
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What is the purpose of identifying an inter-dealer trade executed with, or using the services of, an alternative trading system ("ATS")?
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If a counterparty does not use the ATS indicator, will the two dealers' transaction submission still match on NSCC Real-Time Trade Matching?
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Do transactions executed over the phone with an ATS (i.e., voice trades) require a special condition indicator?
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As of July 18, 2016, dealers are no longer required to report yield on customer trade reports, but MSRB Rule G-15 still obligates dealers to calculate yield for customer confirmations. If a dealer's yield calculation that is used for customer confirmations in order to comply with Rule G-15 differs from the yield disseminated by the MSRB, how can the dealer determine the reason for the difference?
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