Self-Regulatory Organizations; Municipal Securities Rulemaking Board; Notice of Filing of Proposed Amendments to the Real-Time Transaction Reporting System Information System and Subscription Service, 56244-56247 [2012-22395]
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56244
Federal Register / Vol. 77, No. 177 / Wednesday, September 12, 2012 / Notices
(‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
increase position and exercise limits for
EEM options. The proposed rule change
was published for comment in the
Federal Register on July 26, 2012.3 The
Commission received no comment
letters on this proposal.
Section 19(b)(2) of the Act 4 provides
that within 45 days of the publication of
notice of the filing of a proposed rule
change, or within such longer period up
to 90 days as the Commission may
designate if it finds such longer period
to be appropriate and publishes its
reasons for so finding or as to which the
self-regulatory organization consents,
the Commission shall either approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether the
proposed rule change should be
disapproved. The 45th day for this filing
is September 9, 2012. The Commission
is extending this 45-day time period.
The Commission finds it appropriate
to designate a longer period within
which to take action on the proposed
rule change so that it has sufficient time
to consider this proposed rule change,
which would increase the position and
exercise limits for EEM options.
Accordingly, the Commission,
pursuant to Section 19(b)(2) of the Act,5
designates October 24, 2012 as the date
by which the Commission should either
approve or disapprove, or institute
proceedings to determine whether to
disapprove, the proposed rule change
(File No. SR–CBOE–2012–066).
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.6
Kevin M. O’Neill,
Deputy Secretary.
*COM048*[FR Doc. 2012–22393 Filed 9–11–12;
8:45 am]
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BILLING CODE 8011–01–P
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 67478
(July 20, 2012), 77 FR 43897.
4 15 U.S.C. 78s(b)(2).
5 15 U.S.C. 78s(b)(2).
6 17 CFR 200.30–3(a)(31).
2 17
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–67792; File No. SR–MSRB–
2012–07]
Self-Regulatory Organizations;
Municipal Securities Rulemaking
Board; Notice of Filing of Proposed
Amendments to the Real-Time
Transaction Reporting System
Information System and Subscription
Service
September 6, 2012.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (‘‘the
Exchange Act’’) 1 and Rule 19b–4
thereunder,2 notice is hereby given that
on August 24, 2012, the Municipal
Securities Rulemaking Board (‘‘MSRB’’)
filed with the Securities and Exchange
Commission (‘‘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.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The MSRB is filing with the
Commission a proposed rule change
consisting of amendments to the RealTime Transaction Reporting System
(‘‘RTRS’’) information system and
subscription service (collectively,
‘‘proposed rule change’’). The proposed
rule change will enhance the transaction
data publicly disseminated from RTRS
in real-time by including the exact par
value on all transactions with a par
value of $5 million or less and including
an indicator of ‘‘MM+’’ in place of the
exact par value on transactions where
the par value is greater than $5 million.
The exact par value of transactions
where the par value is greater than $5
million would be disseminated from
RTRS five business days later.
The text of the proposed rule change
is available on the MSRB’s Web site at
www.msrb.org/Rules-andInterpretations/SEC-Filings/2012Filings.aspx, 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
1 15
2 17
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U.S.C. 78s(b)(1).
CFR 240.19b–4.
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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
RTRS is a facility for the collection
and dissemination of information about
transactions occurring in the municipal
securities market. Currently, transaction
information disseminated from RTRS
includes the exact par value on all
transactions with a par value of $1
million or less but includes an indicator
of ‘‘1MM+’’ in place of the exact par
value on transactions where the par
value is greater than $1 million. The
exact par value of such transactions is
disseminated from RTRS five business
days later. The proposed rule change
would enhance the transaction data
publicly disseminated from RTRS in
real-time by including the exact par
value on all transactions with a par
value of $5 million or less and including
an indicator of ‘‘MM+’’ in place of the
exact par value on transactions where
the par value is greater than $5 million.
The exact par value of transactions
where the par value is greater than $5
million would be disseminated from
RTRS five business days later.
Background
MSRB Rule G–14, on transaction
reporting, requires brokers, dealers and
municipal securities dealers
(collectively ‘‘dealers’’) to report all
transactions in municipal securities to
RTRS within fifteen minutes of the time
of trade, with limited exceptions. Since
the implementation of RTRS in 2005,
the MSRB has made transaction data
available to the public through
subscription services designed to
achieve the widest possible
dissemination of transaction
information with the goal of ensuring
the fairest and most accurate pricing of
municipal securities transactions.
In addition to subscription services,
MSRB makes publicly available for free
transaction data on the Electronic
Municipal Market Access (EMMA®)
Web site. Since the launch of EMMA as
a pilot in 2008, MSRB has incorporated
into the display of market-wide and
security specific information all
transaction data disseminated from
RTRS so that transaction information
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would be available on the EMMA Web
site simultaneously with the availability
of information to subscribers to the
RTRS subscription service.
Large Trade Size Masking
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In connection with the MSRB’s
predecessor end-of-day trade reporting
system and the subsequent development
of RTRS, MSRB received comments
that, given the prevalence of thinly
traded securities in the municipal
securities market, it sometimes is
possible to identify institutional
investors and dealers by the exact par
value included on trade reports. It was
noted that, where the market for a
specific security is thin and only one or
two dealers are active, revealing the
exact par amount also may convey
information about a dealer’s inventory
(i.e., size of position and acquisition
cost) and allow other dealers to use this
information to trade against the dealer’s
position, thus reducing the incentive for
a dealer to take large positions in these
circumstances.
To address these concerns,
transaction information disseminated
through RTRS subscription services and
displayed on EMMA includes an
indicator of ‘‘1MM+’’ for any trade with
a par value greater than $1 million. This
indicator is replaced with the exact par
value of the trade five business days
later. The MSRB implemented this
approach to help to preserve the
anonymity of trading parties while not
detracting in a substantial way from the
benefits of price transparency.3 The
MSRB noted that it would review this
masking policy as it gains experience
with real-time transparency.4
In January 2012, the Government
Accountability Office (‘‘GAO’’)
published a report on municipal
securities market structure, pricing, and
regulation, as required by Section 977 of
the Dodd-Frank Wall Street Reform and
Consumer Protection Act.5 In this report
the GAO, among other conclusions,
concluded that individual investors
generally have less information about
transaction prices than institutional
investors. The GAO, which had
interviewed a broad range of market
participants, including institutional
investors, observed that: ‘‘Some of these
[institutional] investors said that even
3 See
MSRB Notice 2003–12 (April 7, 2003).
MSRB Notice 2004–13 (June 1, 2004). See
also Exchange Act Release No. 49902 (June 22,
2004), 69 FR 38925 (June 29, 2004), approved
Exchange Act Release No. 50294 (August 31, 2004),
69 FR 54170 (September 7, 2004).
5 U. S. Government Accountability Office,
Municipal Securities: Overview of Market
Structure, Pricing, and Regulation, GAO–12–265,
January 17, 2012.
4 See
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though MSRB’s RTRS system did not
disclose total transaction amounts for
trades over $1 million—which the
system reports as trade amounts of ‘$1+
million’—they typically were aware of
the amount and the price of these large
transactions through their relationships
with broker-dealers.’’
A foundational principal of RTRS is
that all market participants would have
equal access to transaction information.
The GAO observation that certain
market participants are able to
determine, through their relationships
with dealers, the par amount of large
transactions for which the par value is
masked in RTRS subscription services
and on EMMA undermines the purpose
of masking the exact par value. Further,
if certain market participants are able to
determine exact par values yet the
information disseminated by RTRS
masks exact par values, then the
foundational principal of RTRS has
been compromised since the equality of
access to transaction information is lost
for the five business day period that
certain institutional customers have
access to the exact par value while the
rest of the marketplace must await the
unmasking of such information by RTRS
five business days after the trade was
reported.
To ensure that as many market
participants as possible have access to
the same amount of information about
each transaction disseminated from
RTRS and to further promote price
transparency consistent with the
MSRB’s intent to review its masking
policy as it gained experience with realtime transparency, the proposed rule
change would enhance the transaction
data publicly disseminated from RTRS
in real-time by including the exact par
value on all transactions with a par
value of $5 million or less. While the
MSRB considered discontinuing
masking of the exact par value on
transactions where the par value is
greater than $1 million, with the result
that RTRS subscription services and
EMMA would include the exact par
value on all transactions when initially
disseminated to the public, as more
fully discussed in the MSRB’s statement
on comments received on the proposed
rule change, dealers and institutional
investors oppose eliminating the
practice of masking large trade sizes and
cited concerns related to adverse
impacts on liquidity. However, these
commenters stated that raising the par
value threshold for masking large trade
sizes would provide additional
transparency to the municipal market
without adversely impacting liquidity.
Based upon 2011 trade data, the number
of trades that were subject to the over $1
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56245
million trade size mask was 342,906
and, if the trade size mask was raised to
par values over $5 million, this number
would have been 97,124 trades.
The MSRB believes that raising the
par value threshold to par values over
$5 million would be an appropriate first
step to take in the short term as it would
greatly reduce the number of trades
subject to the par value mask. The
MSRB plans to continue to evaluate
whether this threshold can be raised
further or completely eliminated with a
view towards bringing full transparency
of exact par values to the municipal
market in real-time.6 As part of the
MSRB’s Long-Range Plan for Market
Transparency Products,7 the MSRB
plans to undertake an initiative to
reengineer RTRS. Through the RTRS
reengineering initiative, additional
industry comment will be solicited on
long-term measures for increasing
transparency of large trade sizes or
alternative methods of disseminating
such information. MSRB also plans to
evaluate any impacts on liquidity from
the near-term increase of the trade size
mask threshold to $5 million to assist it
in determining whether any future
changes to this threshold are merited or
could result in unanticipated
consequences.
Effective Date of Proposed Rule Change
The MSRB proposes that the proposed
rule change be made effective on
November 5, 2012 to coincide with
other planned changes to RTRS.8
2. Statutory Basis
The MSRB believes that the proposed
rule change is consistent with Section
15B(b)(2)(C) of the Exchange Act, which
provides 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.
6 As part of the proposed rule change, the MSRB
plans to use a different indicator for disseminating
those par values that are greater than $5 million.
Currently, the MSRB disseminates an indicator of
‘‘1MM+’’ to indicate par values greater than $1
million. Instead of changing this to ‘‘5MM+’’, the
MSRB plans to include an indicator of ‘‘MM+’’ so
that the par value threshold could be changed in the
future without requiring subscribers to make system
changes to accommodate a new indicator.
7 See MSRB Notice 2012–06 (February 23, 2012).
8 See MSRB Notice 2012–42 (August 10, 2012).
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two weeks of work for the equivalent of
one full time employee. Some
subscribers to the RTRS subscription
service may bear minimal one-time
programming and/or database costs to
be able to accept and process a value of
‘‘MM+’’ rather than ‘‘1MM+,’’ likely of
equal or lesser magnitude than the costs
the MSRB would bear in making its own
programming changes. The MSRB
believes that an effective date of
November 5, 2012 will provide
subscribers with sufficient time to make
any required changes in due course
without causing material disruptions to
their information technology plans or
budgets.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
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The MSRB believes that the proposed
rule change is consistent with the
Exchange Act. The proposed rule
change would remove impediments to
and perfect the mechanism of a free and
open market in municipal securities by
increasing the number of transactions
disseminated from RTRS in real-time
that include the exact par value, which
would ensure more market participants
have equal access to information about
transactions disseminated from RTRS.
This change would contribute to the
MSRB’s continuing efforts to improve
market transparency and to protect
investors, municipal entities, obligated
persons and the public interest.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
On June 1, 2012, the MSRB published
a notice requesting comment on
enhancing the transaction data publicly
disseminated in real-time from RTRS by
including the exact par value on all
transactions disseminated (‘‘June 2012
Notice’’).10 The June 2012 Notice
solicited input on whether the masking
of trade size has been effective at
achieving its initial purpose. In
addition, the June 2012 Notice sought
comment on whether the benefits, if
any, of retaining such masking outweigh
the potential negative effects of
withholding such information known to
certain institutional investors from the
broader marketplace. Further, the MSRB
sought comment on whether other
methods exist for market participants to
determine the exact or relative size of
large trades and to infer the identity of
parties to the transaction from the RTRS
trade data history, such as through
public filings by certain institutional
investors through the SEC’s EDGAR
system or other sources, that otherwise
undermine the effectiveness of trade
size masking in achieving its initial
purpose. Finally, the June 2012 Notice
requested that market participants
believing that such masking should be
continued should provide justification
for doing so in light of the GAO findings
and the foundational principles for
RTRS, as well as suggestions for
alternatives to discontinuing par value
masking that would further the initial
purpose of such practice while reducing
or eliminating the selective
dissemination of such information.
In response to the June 2012 Notice,
comment letters were received from:
Benchmark Solutions, Bond Dealers of
America (‘‘BDA’’), Government Finance
Officers Association (‘‘GFOA’’),
The MSRB does not believe the
proposed rule change will impose any
burden on competition not necessary or
appropriate in furtherance of the
purposes of the Exchange Act.
Information disseminated by RTRS is
available to all persons on an equal and
non-discriminatory basis. The
information disseminated from RTRS
real-time, including the exact par value
on all transactions with a par value of
$5 million or less, will be available to
all subscribers simultaneously with the
availability of the information through
the EMMA web portal. In addition to
making the information available for
free on the EMMA web portal to all
members of the public, the MSRB makes
the information collected by RTRS
available by subscription on an equal
and non-discriminatory basis without
imposing restrictions on subscribers
from, or imposing additional charges on
subscribers for, re-disseminating such
information or otherwise adding valueadded services and products based on
such information on terms determined
by each subscriber.9
In addition, the proposed rule change
would not impose any burden on
dealers or any other market participant
in connection with the reporting of data
to the MSRB since dealers already are,
and would continue to be, required to
report the full principal amount of
transactions to the MSRB, regardless of
trade size. Thus, no change in submitter
inputs to RTRS would be required. The
large trade size indicator is applied
automatically by the MSRB’s systems
and will require minimal programming
efforts on the part of the MSRB. The
MSRB estimates that implementing the
proposed rule change will require one to
9 The MSRB notes that subscribers may be subject
to proprietary rights of third parties in information
provided by such third parties that is made
available through the subscription.
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10 See
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Investment Company Institute (‘‘ICI’’),
Securities Industry and Financial
Markets Association (‘‘SIFMA’’), and
Stifel Nicolaus. Summaries of those
comments and the MSRB’s responses
follow.
All commenters were supportive of
providing additional transparency of
exact par values of large trades;
however, commenters differed on
whether the practice of masking large
trade sizes should be eliminated
altogether.
Benchmark Solutions and GFOA
stated support for eliminating the
practice of masking large trade sizes.
Benchmark Solutions stated that
disseminating exact par values in realtime would provide investors with
equal access to information and
facilitate pricing bonds in the traded
security as well as in other comparable
securities.11 While GFOA acknowledged
the reasons why the practice of masking
large trade sizes was originally
implemented, it stated that MSRB
should ‘‘look to developing appropriate
guidance to address those concerns
rather than using the masking of pricing
information as a means to this end.’’
BDA, ICI, SIFMA and Stifel Nicolaus
stated opposition to eliminating the
practice of masking large trade sizes.
BDA stated that institutional investors
‘‘may materially alter their trading
practices’’ if exact par values are
disseminated in real-time, which ‘‘may
prove disruptive to the municipal
markets.’’ Stifel Nicolaus noted that
disseminating exact par values in realtime could ‘‘eliminate the anonymity of
the buyer and seller * * * [which] is
valued in the market and assists in the
maintenance of liquidity.’’ SIFMA noted
that ‘‘a significant portion of trading
activity in the municipal market
involves dealers taking bonds into
inventory with no identified buyers’’
and without the anonymity provided by
large trade size masking, it stated that
some dealers that regularly engage in
large block trades ‘‘may become less
willing to bid on investors’ positions.’’
However, SIFMA acknowledged that
other dealers ‘‘stated that eliminating
the mask would not have an effect on
their market activity.’’ ICI stated that
‘‘increased transparency could diminish
market liquidity’’ and noted that
‘‘secondary market liquidity for
investors is provided by dealers that are
willing to risk their capital pending the
11 Benchmark Solutions also provided comments
related to shortening the fifteen minute timeframe
for dealers to report transactions to RTRS. In the
future, the MSRB plans to request comment on
shortening the fifteen minute reporting deadline
and this comment will be considered with any
other comments received at that time.
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location of customers who are willing to
purchase a block of bonds.’’
As an alternative to eliminating the
practice of masking large trade sizes
altogether, ICI, SIFMA and Stifel
Nicolaus suggested that the trade size
masking threshold in RTRS be raised
from the current $1 million level to
those trades in par values that exceed $5
million.12
Discussion. Representatives of both
dealers and institutional investors stated
consistent concerns about the potential
adverse effects on liquidity that could
arise from eliminating the practice of
masking large trade sizes. The MSRB
notes that these commenters did not
refute the GAO observation that certain
market participants are able to
determine, through their relationships
with dealers, the par amount of large
transactions for which the par value is
masked, but acknowledges the
commenters’ view that a certain level of
anonymity continues to exist in the
reports of large trades for which the
exact par value is masked. The MSRB is
sensitive to the views of those
commenters that argued for eliminating
the practice of masking large trade sizes
as it would ensure that a foundational
principal of RTRS to provide all market
participants with equal access to
transaction information is achieved.
However, the comments received did
not provide specific evidence that the
benefits to transparency from
disseminating exact par values in realtime outweigh potential adverse impacts
on liquidity and the MSRB does not
currently have its own data to assess
any such impact. Thus, while the MSRB
continues to believe that the municipal
securities market will benefit from full
transparency on all transactions, the
MSRB has determined that it would be
appropriate to take an initial interim
step toward that ultimate goal that will
allow the MSRB to assess the impact of
such transparency on trades in sizes
ranging between $1 million and $5
million. Information derived from such
interim step would assist the MSRB in
determining whether increased trade
size transparency results in adverse
effects on market liquidity.
12 In response to the question in the June 2012
Notice of whether other methods exist for market
participants to determine the exact or relative size
of large trades and to infer the identity of parties
to the transaction from the RTRS trade data history,
SIFMA noted that the SEC’s EDGAR system does
not serve as a source of such information and that
while there are ‘‘publicly available sources of
information [that] detail[ ] portfolio holdings of
certain institutional investors * * * it is sometimes
not possible to reliably determine actual trade sizes
for 1MM+ trade reports from publicly available
information.’’
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While dealers and institutional
investors oppose eliminating the
practice of masking large trade sizes,
these commenters stated that raising the
par value threshold for masking large
trade sizes would provide additional
transparency to the municipal market
without adversely impacting liquidity.
Based upon 2011 trade data, the number
of trades that were subject to the over $1
million trade size mask was 342,906 and
if the trade size mask was raised to par
values over $5 million, this number
would have been 97,124 trades. MSRB
believes that raising the par value
threshold to par values over $5 million
would be an appropriate first step to
take in the short term as it would greatly
reduce the number of trades subject to
the par value mask. However, as noted
above, the MSRB plans to continue to
evaluate whether this threshold can be
raised with a view towards bringing full
transparency of exact par values to the
municipal market in real-time.
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 (i)
as the Commission may designate up to
90 days of such date 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.
56247
All submissions should refer to File
Number SR–MSRB–2012–07. 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 Web site (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 Web site 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 MSRB’s
offices. All comments received will be
posted without change; the Commission
does not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–MSRB–2012–07, and
should be submitted on or before
October 3, 2012.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.13
Kevin M. O’Neill,
Deputy Secretary.
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:
[FR Doc. 2012–22395 Filed 9–11–12; 8:45 am]
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number SR–MSRB–2012–07 on the
subject line.
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Suspension of and Order
Instituting Proceedings To Determine
Whether To Approve or Disapprove a
Proposed Rule Change To Amend the
Customer Large Trade Discount
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street NE., Washington, DC
20549–1090.
I. Introduction
On July 11, 2012, Chicago Board
Options Exchange, Incorporated
(‘‘CBOE’’ or ‘‘Exchange’’) filed with the
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BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–67794; File No. SR–CBOE–
2012–068]
September 6, 2012.
13 17
E:\FR\FM\12SEN1.SGM
CFR 200.30–3(a)(12).
12SEN1
Agencies
[Federal Register Volume 77, Number 177 (Wednesday, September 12, 2012)]
[Notices]
[Pages 56244-56247]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-22395]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-67792; File No. SR-MSRB-2012-07]
Self-Regulatory Organizations; Municipal Securities Rulemaking
Board; Notice of Filing of Proposed Amendments to the Real-Time
Transaction Reporting System Information System and Subscription
Service
September 6, 2012.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``the Exchange Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is
hereby given that on August 24, 2012, the Municipal Securities
Rulemaking Board (``MSRB'') filed with the Securities and Exchange
Commission (``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 is filing with the Commission a proposed rule change
consisting of amendments to the Real-Time Transaction Reporting System
(``RTRS'') information system and subscription service (collectively,
``proposed rule change''). The proposed rule change will enhance the
transaction data publicly disseminated from RTRS in real-time by
including the exact par value on all transactions with a par value of
$5 million or less and including an indicator of ``MM+'' in place of
the exact par value on transactions where the par value is greater than
$5 million. The exact par value of transactions where the par value is
greater than $5 million would be disseminated from RTRS five business
days later.
The text of the proposed rule change is available on the MSRB's Web
site at www.msrb.org/Rules-and-Interpretations/SEC-Filings/2012-Filings.aspx, 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
RTRS is a facility for the collection and dissemination of
information about transactions occurring in the municipal securities
market. Currently, transaction information disseminated from RTRS
includes the exact par value on all transactions with a par value of $1
million or less but includes an indicator of ``1MM+'' in place of the
exact par value on transactions where the par value is greater than $1
million. The exact par value of such transactions is disseminated from
RTRS five business days later. The proposed rule change would enhance
the transaction data publicly disseminated from RTRS in real-time by
including the exact par value on all transactions with a par value of
$5 million or less and including an indicator of ``MM+'' in place of
the exact par value on transactions where the par value is greater than
$5 million. The exact par value of transactions where the par value is
greater than $5 million would be disseminated from RTRS five business
days later.
Background
MSRB Rule G-14, on transaction reporting, requires brokers, dealers
and municipal securities dealers (collectively ``dealers'') to report
all transactions in municipal securities to RTRS within fifteen minutes
of the time of trade, with limited exceptions. Since the implementation
of RTRS in 2005, the MSRB has made transaction data available to the
public through subscription services designed to achieve the widest
possible dissemination of transaction information with the goal of
ensuring the fairest and most accurate pricing of municipal securities
transactions.
In addition to subscription services, MSRB makes publicly available
for free transaction data on the Electronic Municipal Market Access
(EMMA[supreg]) Web site. Since the launch of EMMA as a pilot in 2008,
MSRB has incorporated into the display of market-wide and security
specific information all transaction data disseminated from RTRS so
that transaction information
[[Page 56245]]
would be available on the EMMA Web site simultaneously with the
availability of information to subscribers to the RTRS subscription
service.
Large Trade Size Masking
In connection with the MSRB's predecessor end-of-day trade
reporting system and the subsequent development of RTRS, MSRB received
comments that, given the prevalence of thinly traded securities in the
municipal securities market, it sometimes is possible to identify
institutional investors and dealers by the exact par value included on
trade reports. It was noted that, where the market for a specific
security is thin and only one or two dealers are active, revealing the
exact par amount also may convey information about a dealer's inventory
(i.e., size of position and acquisition cost) and allow other dealers
to use this information to trade against the dealer's position, thus
reducing the incentive for a dealer to take large positions in these
circumstances.
To address these concerns, transaction information disseminated
through RTRS subscription services and displayed on EMMA includes an
indicator of ``1MM+'' for any trade with a par value greater than $1
million. This indicator is replaced with the exact par value of the
trade five business days later. The MSRB implemented this approach to
help to preserve the anonymity of trading parties while not detracting
in a substantial way from the benefits of price transparency.\3\ The
MSRB noted that it would review this masking policy as it gains
experience with real-time transparency.\4\
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\3\ See MSRB Notice 2003-12 (April 7, 2003).
\4\ See MSRB Notice 2004-13 (June 1, 2004). See also Exchange
Act Release No. 49902 (June 22, 2004), 69 FR 38925 (June 29, 2004),
approved Exchange Act Release No. 50294 (August 31, 2004), 69 FR
54170 (September 7, 2004).
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In January 2012, the Government Accountability Office (``GAO'')
published a report on municipal securities market structure, pricing,
and regulation, as required by Section 977 of the Dodd-Frank Wall
Street Reform and Consumer Protection Act.\5\ In this report the GAO,
among other conclusions, concluded that individual investors generally
have less information about transaction prices than institutional
investors. The GAO, which had interviewed a broad range of market
participants, including institutional investors, observed that: ``Some
of these [institutional] investors said that even though MSRB's RTRS
system did not disclose total transaction amounts for trades over $1
million--which the system reports as trade amounts of `$1+ million'--
they typically were aware of the amount and the price of these large
transactions through their relationships with broker-dealers.''
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\5\ U. S. Government Accountability Office, Municipal
Securities: Overview of Market Structure, Pricing, and Regulation,
GAO-12-265, January 17, 2012.
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A foundational principal of RTRS is that all market participants
would have equal access to transaction information. The GAO observation
that certain market participants are able to determine, through their
relationships with dealers, the par amount of large transactions for
which the par value is masked in RTRS subscription services and on EMMA
undermines the purpose of masking the exact par value. Further, if
certain market participants are able to determine exact par values yet
the information disseminated by RTRS masks exact par values, then the
foundational principal of RTRS has been compromised since the equality
of access to transaction information is lost for the five business day
period that certain institutional customers have access to the exact
par value while the rest of the marketplace must await the unmasking of
such information by RTRS five business days after the trade was
reported.
To ensure that as many market participants as possible have access
to the same amount of information about each transaction disseminated
from RTRS and to further promote price transparency consistent with the
MSRB's intent to review its masking policy as it gained experience with
real-time transparency, the proposed rule change would enhance the
transaction data publicly disseminated from RTRS in real-time by
including the exact par value on all transactions with a par value of
$5 million or less. While the MSRB considered discontinuing masking of
the exact par value on transactions where the par value is greater than
$1 million, with the result that RTRS subscription services and EMMA
would include the exact par value on all transactions when initially
disseminated to the public, as more fully discussed in the MSRB's
statement on comments received on the proposed rule change, dealers and
institutional investors oppose eliminating the practice of masking
large trade sizes and cited concerns related to adverse impacts on
liquidity. However, these commenters stated that raising the par value
threshold for masking large trade sizes would provide additional
transparency to the municipal market without adversely impacting
liquidity. Based upon 2011 trade data, the number of trades that were
subject to the over $1 million trade size mask was 342,906 and, if the
trade size mask was raised to par values over $5 million, this number
would have been 97,124 trades.
The MSRB believes that raising the par value threshold to par
values over $5 million would be an appropriate first step to take in
the short term as it would greatly reduce the number of trades subject
to the par value mask. The MSRB plans to continue to evaluate whether
this threshold can be raised further or completely eliminated with a
view towards bringing full transparency of exact par values to the
municipal market in real-time.\6\ As part of the MSRB's Long-Range Plan
for Market Transparency Products,\7\ the MSRB plans to undertake an
initiative to reengineer RTRS. Through the RTRS reengineering
initiative, additional industry comment will be solicited on long-term
measures for increasing transparency of large trade sizes or
alternative methods of disseminating such information. MSRB also plans
to evaluate any impacts on liquidity from the near-term increase of the
trade size mask threshold to $5 million to assist it in determining
whether any future changes to this threshold are merited or could
result in unanticipated consequences.
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\6\ As part of the proposed rule change, the MSRB plans to use a
different indicator for disseminating those par values that are
greater than $5 million. Currently, the MSRB disseminates an
indicator of ``1MM+'' to indicate par values greater than $1
million. Instead of changing this to ``5MM+'', the MSRB plans to
include an indicator of ``MM+'' so that the par value threshold
could be changed in the future without requiring subscribers to make
system changes to accommodate a new indicator.
\7\ See MSRB Notice 2012-06 (February 23, 2012).
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Effective Date of Proposed Rule Change
The MSRB proposes that the proposed rule change be made effective
on November 5, 2012 to coincide with other planned changes to RTRS.\8\
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\8\ See MSRB Notice 2012-42 (August 10, 2012).
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2. Statutory Basis
The MSRB believes that the proposed rule change is consistent with
Section 15B(b)(2)(C) of the Exchange Act, which provides 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.
[[Page 56246]]
The MSRB believes that the proposed rule change is consistent with
the Exchange Act. The proposed rule change would remove impediments to
and perfect the mechanism of a free and open market in municipal
securities by increasing the number of transactions disseminated from
RTRS in real-time that include the exact par value, which would ensure
more market participants have equal access to information about
transactions disseminated from RTRS. This change would contribute to
the MSRB's continuing efforts to improve market transparency and to
protect investors, municipal entities, obligated persons and the public
interest.
B. Self-Regulatory Organization's Statement on Burden on Competition
The MSRB does not believe the proposed rule change will impose any
burden on competition not necessary or appropriate in furtherance of
the purposes of the Exchange Act. Information disseminated by RTRS is
available to all persons on an equal and non-discriminatory basis. The
information disseminated from RTRS real-time, including the exact par
value on all transactions with a par value of $5 million or less, will
be available to all subscribers simultaneously with the availability of
the information through the EMMA web portal. In addition to making the
information available for free on the EMMA web portal to all members of
the public, the MSRB makes the information collected by RTRS available
by subscription on an equal and non-discriminatory basis without
imposing restrictions on subscribers from, or imposing additional
charges on subscribers for, re-disseminating such information or
otherwise adding value-added services and products based on such
information on terms determined by each subscriber.\9\
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\9\ The MSRB notes that subscribers may be subject to
proprietary rights of third parties in information provided by such
third parties that is made available through the subscription.
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In addition, the proposed rule change would not impose any burden
on dealers or any other market participant in connection with the
reporting of data to the MSRB since dealers already are, and would
continue to be, required to report the full principal amount of
transactions to the MSRB, regardless of trade size. Thus, no change in
submitter inputs to RTRS would be required. The large trade size
indicator is applied automatically by the MSRB's systems and will
require minimal programming efforts on the part of the MSRB. The MSRB
estimates that implementing the proposed rule change will require one
to two weeks of work for the equivalent of one full time employee. Some
subscribers to the RTRS subscription service may bear minimal one-time
programming and/or database costs to be able to accept and process a
value of ``MM+'' rather than ``1MM+,'' likely of equal or lesser
magnitude than the costs the MSRB would bear in making its own
programming changes. The MSRB believes that an effective date of
November 5, 2012 will provide subscribers with sufficient time to make
any required changes in due course without causing material disruptions
to their information technology plans or budgets.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
On June 1, 2012, the MSRB published a notice requesting comment on
enhancing the transaction data publicly disseminated in real-time from
RTRS by including the exact par value on all transactions disseminated
(``June 2012 Notice'').\10\ The June 2012 Notice solicited input on
whether the masking of trade size has been effective at achieving its
initial purpose. In addition, the June 2012 Notice sought comment on
whether the benefits, if any, of retaining such masking outweigh the
potential negative effects of withholding such information known to
certain institutional investors from the broader marketplace. Further,
the MSRB sought comment on whether other methods exist for market
participants to determine the exact or relative size of large trades
and to infer the identity of parties to the transaction from the RTRS
trade data history, such as through public filings by certain
institutional investors through the SEC's EDGAR system or other
sources, that otherwise undermine the effectiveness of trade size
masking in achieving its initial purpose. Finally, the June 2012 Notice
requested that market participants believing that such masking should
be continued should provide justification for doing so in light of the
GAO findings and the foundational principles for RTRS, as well as
suggestions for alternatives to discontinuing par value masking that
would further the initial purpose of such practice while reducing or
eliminating the selective dissemination of such information.
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\10\ See MSRB Notice 2012-29 (June 1, 2012).
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In response to the June 2012 Notice, comment letters were received
from: Benchmark Solutions, Bond Dealers of America (``BDA''),
Government Finance Officers Association (``GFOA''), Investment Company
Institute (``ICI''), Securities Industry and Financial Markets
Association (``SIFMA''), and Stifel Nicolaus. Summaries of those
comments and the MSRB's responses follow.
All commenters were supportive of providing additional transparency
of exact par values of large trades; however, commenters differed on
whether the practice of masking large trade sizes should be eliminated
altogether.
Benchmark Solutions and GFOA stated support for eliminating the
practice of masking large trade sizes. Benchmark Solutions stated that
disseminating exact par values in real-time would provide investors
with equal access to information and facilitate pricing bonds in the
traded security as well as in other comparable securities.\11\ While
GFOA acknowledged the reasons why the practice of masking large trade
sizes was originally implemented, it stated that MSRB should ``look to
developing appropriate guidance to address those concerns rather than
using the masking of pricing information as a means to this end.''
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\11\ Benchmark Solutions also provided comments related to
shortening the fifteen minute timeframe for dealers to report
transactions to RTRS. In the future, the MSRB plans to request
comment on shortening the fifteen minute reporting deadline and this
comment will be considered with any other comments received at that
time.
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BDA, ICI, SIFMA and Stifel Nicolaus stated opposition to
eliminating the practice of masking large trade sizes. BDA stated that
institutional investors ``may materially alter their trading
practices'' if exact par values are disseminated in real-time, which
``may prove disruptive to the municipal markets.'' Stifel Nicolaus
noted that disseminating exact par values in real-time could
``eliminate the anonymity of the buyer and seller * * * [which] is
valued in the market and assists in the maintenance of liquidity.''
SIFMA noted that ``a significant portion of trading activity in the
municipal market involves dealers taking bonds into inventory with no
identified buyers'' and without the anonymity provided by large trade
size masking, it stated that some dealers that regularly engage in
large block trades ``may become less willing to bid on investors'
positions.'' However, SIFMA acknowledged that other dealers ``stated
that eliminating the mask would not have an effect on their market
activity.'' ICI stated that ``increased transparency could diminish
market liquidity'' and noted that ``secondary market liquidity for
investors is provided by dealers that are willing to risk their capital
pending the
[[Page 56247]]
location of customers who are willing to purchase a block of bonds.''
As an alternative to eliminating the practice of masking large
trade sizes altogether, ICI, SIFMA and Stifel Nicolaus suggested that
the trade size masking threshold in RTRS be raised from the current $1
million level to those trades in par values that exceed $5 million.\12\
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\12\ In response to the question in the June 2012 Notice of
whether other methods exist for market participants to determine the
exact or relative size of large trades and to infer the identity of
parties to the transaction from the RTRS trade data history, SIFMA
noted that the SEC's EDGAR system does not serve as a source of such
information and that while there are ``publicly available sources of
information [that] detail[ ] portfolio holdings of certain
institutional investors * * * it is sometimes not possible to
reliably determine actual trade sizes for 1MM+ trade reports from
publicly available information.''
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Discussion. Representatives of both dealers and institutional
investors stated consistent concerns about the potential adverse
effects on liquidity that could arise from eliminating the practice of
masking large trade sizes. The MSRB notes that these commenters did not
refute the GAO observation that certain market participants are able to
determine, through their relationships with dealers, the par amount of
large transactions for which the par value is masked, but acknowledges
the commenters' view that a certain level of anonymity continues to
exist in the reports of large trades for which the exact par value is
masked. The MSRB is sensitive to the views of those commenters that
argued for eliminating the practice of masking large trade sizes as it
would ensure that a foundational principal of RTRS to provide all
market participants with equal access to transaction information is
achieved. However, the comments received did not provide specific
evidence that the benefits to transparency from disseminating exact par
values in real-time outweigh potential adverse impacts on liquidity and
the MSRB does not currently have its own data to assess any such
impact. Thus, while the MSRB continues to believe that the municipal
securities market will benefit from full transparency on all
transactions, the MSRB has determined that it would be appropriate to
take an initial interim step toward that ultimate goal that will allow
the MSRB to assess the impact of such transparency on trades in sizes
ranging between $1 million and $5 million. Information derived from
such interim step would assist the MSRB in determining whether
increased trade size transparency results in adverse effects on market
liquidity.
While dealers and institutional investors oppose eliminating the
practice of masking large trade sizes, these commenters stated that
raising the par value threshold for masking large trade sizes would
provide additional transparency to the municipal market without
adversely impacting liquidity. Based upon 2011 trade data, the number
of trades that were subject to the over $1 million trade size mask was
342,906 and if the trade size mask was raised to par values over $5
million, this number would have been 97,124 trades. MSRB believes that
raising the par value threshold to par values over $5 million would be
an appropriate first step to take in the short term as it would greatly
reduce the number of trades subject to the par value mask. However, as
noted above, the MSRB plans to continue to evaluate whether this
threshold can be raised with a view towards bringing full transparency
of exact par values to the municipal market in real-time.
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 (i) as the Commission may
designate up to 90 days of such date 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 rule-comments@sec.gov. Please include
File Number SR-MSRB-2012-07 on the subject line.
Paper Comments
Send paper comments in triplicate to Elizabeth M. Murphy,
Secretary, Securities and Exchange Commission, 100 F Street NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number SR-MSRB-2012-07. 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 Web site (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 Web site 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 MSRB's offices. All comments received
will be posted without change; the Commission does not edit personal
identifying information from submissions. You should submit only
information that you wish to make available publicly. All submissions
should refer to File Number SR-MSRB-2012-07, and should be submitted on
or before October 3, 2012.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\13\
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\13\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2012-22395 Filed 9-11-12; 8:45 am]
BILLING CODE 8011-01-P