MSRB Report Cards

MSRB G-15(f) Trades Below Minimum Denomination Report

The MSRB G-15(f) Trades Below Minimum Denomination Report is published on a monthly basis to assist firms with monitoring their compliance and supervision of customer trades. MSRB Rule G-15(f) prohibits a broker, dealer or municipal securities dealer from effecting a customer transaction in municipal securities issued after June 1, 2002, in an amount lower than the minimum denomination of the issue. This monthly report identifies any customer trades of municipal securities where the number of bonds was less than the minimum denomination provided to DTCC’s New Issue Information Dissemination Service (NIIDS).

The G-15(f) Report includes:

a count of trades in par values below the minimum denominations;
customer transaction-based peer group data;
peer and industry comparisons; and
the ability to filter the report by purchases from customers or sales to customers.

Note: The report relies on information provided to DTCC’s NIIDS service by municipal underwriters pursuant to MSRB Rule G-34, and evaluates only transactions in securities for which information was provided to NIIDS beginning in mid-2012. The report does not account for incorrect entries to the NIIDS system and potential changes to the minimum denomination that may occur during the existence of a security. Firms should refer to the security’s official statement for complete minimum denomination information.

Municipal Bond Underwriting Report Card

Effective on June 1, 2009, amended MSRB Rule G-32 consolidated the filing requirements of former Rule G-36 and the official statement delivery requirements of former Rule G-32. FINRA provides the MSRB G-32 report card to help underwriters of municipal securities analyze and improve compliance with MSRB Rule G-32 and related reporting to the MSRB's Electronic Municipal Market Access System (EMMA). Published on a monthly basis, the report contains two views of a firm's data:

The MSRB G-32 Report Card Summary provides a rolling 12 months of statistics on a firm's G-32 document, exemption, and cancellation submissions to EMMA.
The MSRB G-32 Submitted Filing Details view of the report displays details of each document submitted to EMMA during the month, including document (or exemption) type, Issuer Name and Issue Description, CUSIPs, and closing date.

More information on MSRB Rule G-32.

Note: All filing information contained in this report has been provided by the MSRB and its accuracy has not been verified by FINRA. If inaccuracies are discovered or you have questions regarding the content of this specific report, please contact FINRA Member Regulation at (202) 728-8133.

For more information on the MSRB G-32 Report Cards, view the tutorials.

Please note: MSRB Rule G-32 has replaced MSRB Rule G-36, effective June 1, 2009; as a result, the MSRB G-36 Report Card is no longer being published.

Municipal Continuing Disclosure Report

To assist firms with meeting SEC and MSRB customer disclosure requirements for municipal securities (see FINRA Notice 10-41), this monthly report helps firms review municipal security trade activity. Specifically, it identifies trades involving municipal securities in which key disclosure information (e.g., official statements and financial information) was not available on the MSRB's Electronic Municipal Market Access system (EMMA) when the trade was made, and also those trades involving securities that have been the subject of a disclosure through EMMA during a certain time period.

The report includes summary data, including counts and other statistics, and detail data about specific trades. Firms can use this information to assist in reviewing their municipal bond sales to help determine if they are taking available information into consideration and making appropriate disclosures of material information at the time of trade.

Note: As of March 2014, the Municipal Continuing Disclosure Report was enhanced to include all customer-related trades. In addition to this change, the report was updated with:

Three “views” for the report:
- All - includes counts for sales to customers and purchases from customers.
- Sales - filtered to include only sales to customers.
- Buys - filtered to include only purchases from customers.
  Note that transaction records are from the broker-dealer’s perspective.
Peer Group and Industry Rankings
- Trade report volume-based peer groups.
- Monthly comparisons and peer group determinations are specific to the report view (all, sales, purchases).
- Firms have the ability to see which firms comprise their peer groups.
Update to the report’s associated detail data to identify trades that were sales to customers and purchases from customers.
Update to the related Ad Hoc Query tool to support filtering by trade type.

Municipal Primary Offering Disclosure Report

The Municipal Primary Offering Disclosure Report is published on a monthly basis to help firms monitor their compliance with the disclosure requirements of MSRB Rule G-32(a), which apply to all broker-dealers that sell municipal securities. MSRB Rule G-32(a) requires firms to provide customers with an official statement (or a notice explaining how the OS may be obtained from the EMMA Web site) if a municipal transaction occurs within the primary offering disclosure period, as defined in Rule G-32(d)(ix). This requirement applies to secondary market transactions as well as to primary market transactions, as long as they occur during the primary offering disclosure period.

The report provides firms a rolling 12 months of statistics related to their municipal bond transactions with customers, and allows firms to request details of the transactions subject to the OS delivery requirement. It is important to note that the report does not indicate whether the firm provided documentation required by MSRB Rule G-32 for each transaction—instead, it identifies those transactions to help firms ensure appropriate customer disclosure procedures are in place and have been followed.

For questions or help, contact the Report Center administrator.