Self-Regulatory Organizations; Municipal Securities Rulemaking Board; Notice of Filing of a Proposed Rule Change Consisting of Proposed Amendments to the MSRB Rule G-14 RTRS Procedures, and the Real-Time Transaction Reporting System and Subscription Service, 16466-16471 [2015-06993]
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Federal Register / Vol. 80, No. 59 / Friday, March 27, 2015 / Notices
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[Release No. 34–74564; File No. SR–MSRB–
2015–02]
Self-Regulatory Organizations;
Municipal Securities Rulemaking
Board; Notice of Filing of a Proposed
Rule Change Consisting of Proposed
Amendments to the MSRB Rule G–14
RTRS Procedures, and the Real-Time
Transaction Reporting System and
Subscription Service
March 23, 2015.
mstockstill on DSK4VPTVN1PROD with NOTICES
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on March 19,
2015, the Municipal Securities
Rulemaking Board (the ‘‘MSRB’’ or
‘‘Board’’) filed with the Securities and
Exchange Commission (the ‘‘SEC’’ or
‘‘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 filed with the Commission
a proposed rule change consisting of
proposed amendments to the MSRB
Rule G–14 RTRS Procedures, and the
Real-Time Transaction Reporting
System and subscription service
(collectively, the ‘‘proposed rule
change’’). The MSRB is proposing that
1 15
2 17
U.S.C. 78s(b)(1).
CFR 240.19b–4.
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the effective date for the proposed rule
change be no later than May 23, 2016
and announced by the MSRB in a notice
published on the MSRB Web site no
later than sixty (60) days prior to the
effective date.
The text of the proposed rule change
is available on the MSRB’s Web site at
www.msrb.org/Rules-andInterpretations/SEC-Filings/2015Filings.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
MSRB Rule G–14, on reports of sales
or purchases, requires brokers, dealers
and municipal securities dealers
(collectively ‘‘dealers’’) to report all
executed transactions in municipal
securities to RTRS within 15 minutes of
the time of trade, with limited
exceptions.3 RTRS serves the dual
objectives of price transparency and
market surveillance. Because a
comprehensive database of transactions
is needed for the surveillance function
of RTRS, Rule G–14, with limited
exceptions, requires dealers to report all
of their purchase-sale transactions to
RTRS, not only those that qualify for
public dissemination to serve the
transparency function of the system.4
The MSRB makes transaction data
available to the general public through
3 Transactions in securities without CUSIP
numbers, in municipal fund securities, and certain
inter-dealer securities movements not eligible for
comparison through a clearing agency are the only
transactions exempt from the reporting
requirements of Rule G–14.
4 In this respect, RTRS serves as an audit trail for
municipal securities trading, with the exception of
certain internal movements of securities within
dealers that currently are not required to be
reported, customer identifications, and other related
specific items of information. Compare
Consolidated Audit Trail, Release No. 34–67457
(July 18, 2012), 77 FR 45722 (August 1, 2012), File
No. S7–11–10.
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the Electronic Municipal Market Access
(‘‘EMMA’’) Web site at no cost, and
disseminates such data through paid
subscription services to market data
vendors, institutional market
participants and others that subscribe to
the data feed.
As more fully described below, the
proposed rule change would enhance
the post-trade price transparency
information provided through RTRS by:
• Expanding the application of the
existing list offering price and takedown
indicator to cases involving distribution
participant dealers and takedown
transactions that are not at a discount
from the list offering price;
• eliminating the requirement for
dealers to report yield on customer trade
reports and, instead, enabling the MSRB
to calculate and disseminate yield on
customer trades;
• establishing a new indicator for
customer trades involving nontransaction-based compensation
arrangements; and
• establishing a new indicator for
alternative trading system (‘‘ATS’’)
transactions.
Expanding the Application of Existing
List Offering Price and RTRS Takedown
Indicator
Transaction reporting procedures
require dealers that are part of the
underwriting group for a new issuance
of municipal securities to include an
indicator on trade reports, which
indicator is disseminated to the public,
for transactions executed on the first
day of trading in a new issue with prices
set under an offering agreement for the
new issue. These transactions include
sales to customers by a sole underwriter,
syndicate manager, syndicate member
or selling group member at the
published list offering price for the
security (‘‘List Offering Price
Transaction’’) or by a sole underwriter
or syndicate manager to a syndicate or
selling group member at a discount from
the published list offering price for the
security (‘‘RTRS Takedown
Transaction’’). Such trade reports are
provided an end-of-day exception from
Rule G–14’s general 15-minute reporting
requirement.
Since the introduction of the List
Offering Price Transaction indicator in
2005 and RTRS Takedown Transaction
indicator in 2007, certain market
practices in this area have evolved.
First, outside of traditional underwriting
syndicates or selling groups, some
dealers have entered into long-term
marketing arrangements with other
dealers that serve in the syndicate or
selling group relating to purchases and
re-sales of new issue securities
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Since April 30, 2012, the MSRB has
calculated and included in
disseminated RTRS information the
yield on inter-dealer trades computed in
the same manner as required for
customer trades.6
The proposed rule change would
eliminate the requirement for dealers to
include yield on customer trade
reports.7 Consistent with the manner in
which the MSRB calculates and
includes in disseminated RTRS
information yield on inter-dealer trades,
the MSRB would calculate and
disseminate yield on customer trade
reports.8 This would remove one aspect
of a dealer’s burden in reporting
customer transactions to the MSRB in
compliance with MSRB Rule G–14 9 and
ensure that the calculation and
dissemination of yields for both interdealer and customer transactions are
consistent.
Eliminating the Requirement for Dealers
To Report Yield on Customer Trade
Reports
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(‘‘distribution participant dealers’’). The
MSRB understands that these
distribution participant dealers agree to
execute transactions with customers at
the published list offering prices.
Accordingly, the proposed rule change
would expand the application of List
Offering Price Transaction and RTRS
Takedown Transaction indicators to sale
transactions by distribution participant
dealers to customers at the list offering
price and sale transactions by a sole
underwriter or syndicate manager to
distribution participant dealers.
A second evolution in market practice
in this area relates to the prices at which
takedown transactions occur. The RTRS
Takedown Transaction indicator
currently is limited to inter-dealer
transactions occurring at a discount
from the published list offering price.
The MSRB understands that, in some
new issues, transactions between a sole
underwriter or syndicate manager to a
syndicate member, selling group
member or distribution participant
dealer are not executed at a discount
from the published list offering price or
at the full takedown amount. This
typically occurs in the case of group net
or net designated order arrangements.
The proposed rule change expands the
application of the RTRS Takedown
Transaction indicator to any sale
transaction by a sole underwriter or
syndicate manager to a syndicate
member, selling group member or
distribution participant dealer on the
first day of trading in the new issue.
6 See ‘‘SEC Approves Amendments to MSRB Rule
G–14, on Reports of Sales or Purchases, Including
Rule G–14 RTRS Procedures, and Amendments to
the Real-Time Transaction Reporting System,’’
MSRB Notice 2012–15 (March 21, 2012).
7 This change is anticipated to also have the
benefit of alleviating particular operational
concerns cited by dealers in connection with
reporting certain ‘‘away from market’’ trade reports.
8 Note that dealers would continue to be able to
report that a when, as and if issued transaction was
executed on the basis of yield in the event that the
settlement date is not known at the time the trade
is executed, which prevents an accurate calculation
of the corresponding dollar price to be performed.
9 RTRS currently performs price/yield
calculations, compares RTRS-computed values to
dealer-reported values, and returns errors to dealers
when discrepancies are found. This results in
dealers researching and responding to such errors
which, in many cases, are the results of differences
in vendor-provided security descriptive information
utilized by dealers and RTRS. By removing the
requirement to include yield on customer trade
reports, the proposed rule change would have the
effect of eliminating these errors. In addition, in the
case of transactions arising from customer
repurchase agreements, the proposed rule change
would eliminate the burden on dealers of
calculating for trade reporting purposes a yield
consistent with the requirements of Rule G–15(a),
which the MSRB understands presents operational
challenges given that this represents a different
calculation from the calculation used to determine
the yield resulting from the terms of the repurchase
agreement.
Transaction reporting procedures
currently require dealers to include on
most reports of customer transactions to
RTRS both a dollar price and yield.5
The yield required to be reported to
RTRS for customer trades is consistent
with the yield required to be displayed
on a customer confirmation under Rule
G–15(a), which requires that yield be
computed to the lower of an ‘‘in whole’’
call or maturity, subject to certain
requirements set forth in the rule for
specific special situations (generally
referred to as the ‘‘yield to worst’’). Rule
G–15(a) requires the confirmation to
include the date to which yield is
calculated if that date is other than the
nominal maturity date, and also requires
the confirmation for a transaction
effected based on a yield other than
yield to worst to include both yields.
5 For inter-dealer transactions, dealers report the
dollar price at which the transaction was effected
and the MSRB calculates and includes in
disseminated information the corresponding yield.
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Establishing a New Indicator for
Customer Trades Involving NonTransaction-Based Compensation
Arrangements
For principal transactions by dealers,
the trade price reported to and publicly
disseminated by the MSRB includes all
aspects of the price, including any
mark-up or mark-down that
compensates the dealer for executing
the transaction. In agency transactions,
dealers are required to report to the
MSRB both the price of the security and
the commission charged to the
customer. The prices publicly
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disseminated for agency transactions
incorporate the reported commission to
provide for comparability with the
prices for principal trades. However,
dealers effecting transactions with
customers as part of an arrangement that
does not provide for dealer
compensation to be paid on a
transaction-based basis, such as in
certain wrap fee arrangements, report to
the MSRB transaction prices that do not
include a compensation component.
To distinguish in the transaction
information disseminated publicly
between customer transactions that do
not include a dealer compensation
component and those that include a
mark-up or mark-down or a
commission, the proposed rule change
would require dealers to include a new
indicator on their trade reports that
would be disseminated publicly. This
would improve the usefulness of the
transaction information disseminated
publicly by enabling users of the price
transparency information to distinguish
those customer transactions that do not
include a dealer compensation
component.
Establishing a New Indicator for ATS
Transactions
Dealers may use a variety of means to
transact in municipal securities,
including broker’s brokers or ATSs as
well as traditional direct transactions
with a known counterparty. The MSRB
currently identifies all transactions
reported as having been executed by a
broker’s broker in the transaction
information disseminated publicly. This
identifier is applied based on the
broker’s broker informing the MSRB that
it acts in such capacity. The MSRB does
not currently identify trades as having
been executed through an ATS.
To better ascertain the extent to which
ATSs are used in the municipal market
and to indicate to market participants
on disseminated transaction information
that an ATS was used, the proposed rule
change would establish an additional
new indicator. For those ATSs that take
a principal position between a buyer
and seller, the ATS and the dealers that
transact with the ATS would be
required to include the ATS indicator
on trade reports. In instances where an
ATS connects a buyer and seller but
does not take a principal or agency
position between those parties and
therefore does not have a transaction
reporting requirement under MSRB
rules, the dealers that transact with each
other as a result of using the services of
the ATS would be required to include
the ATS indicator on their trade reports.
In all cases, the ATS indicator would be
included on transaction information
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disseminated publicly. Identifying in
disseminated transaction information
that an ATS was employed should
facilitate higher quality research and
analysis of market structure by
providing information about the extent
to which ATSs are used and should
complement the existing indicator
disseminated for transactions involving
a broker’s broker.
Effective Date of the Proposed Rule
Change
To provide time for the MSRB to
undertake the programming changes to
implement the proposed rule change, as
well as to provide an adequate testing
period for dealers and subscribers that
interface with RTRS, the MSRB is
proposing an effective date for the
proposed rule change to be announced
by the MSRB in a notice published on
the MSRB Web site, which date shall be
no later than May 23, 2016 and shall be
announced no later than sixty (60) days
prior to the effective date.
2. Statutory Basis
The MSRB believes that the proposed
rule change is consistent with Section
15B(b)(2)(C) of the Act, which provides
that the MSRB’s rules shall:
mstockstill on DSK4VPTVN1PROD with NOTICES
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.
The MSRB believes that the proposed
rule change is consistent with the Act.
The MSRB believes that the proposed
rule change would remove impediments
to and perfect the mechanism of a free
and open market in municipal securities
by increasing the quality and usefulness
of the post-trade price transparency
information provided through RTRS.
The MSRB believes the expansion of the
application of the existing list offering
price and takedown indicator to cases
involving distribution participant
dealers and takedown transactions that
are not at a discount from the list
offering price, establishment of a new
indicator for customer trades involving
non-transaction-based compensation
arrangements, and establishment of a
new indicator for ATS transactions
would enable users of the post-trade
price transparency information
provided through RTRS to better
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understand the pricing of certain
transactions as well as how such
transactions were executed. As
previously noted, identifying in
disseminated transaction information
that an ATS was employed should
facilitate higher quality research and
analysis of market structure by
providing information about the extent
to which ATSs are used and should
complement the existing indicator
disseminated for transactions involving
a broker’s broker. Accordingly, the
proposed rule 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 would impose any
burden on competition not necessary or
appropriate in furtherance of the
purposes of the Act. Information
disseminated by RTRS is available to all
persons on an equal and nondiscriminatory basis. 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 providing
value-added services and products to
third parties based on such information
on terms determined by each
subscriber.10
The MSRB recognizes that the
proposed rule change would impose a
burden on dealers and subscribers that
interface with RTRS to comply with the
reporting and dissemination of the new
indicators that would be required by the
proposed rule change. The MSRB
solicited and received comment on
several potential burdens of the
proposed rule change and the specific
comments and responses thereto are
discussed below.11 The MSRB plans to
provide a six month testing period in
advance of the effective date. The MSRB
believes that a six month testing period
in advance of the effective date would
provide dealers and subscribers with
10 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.
11 See ‘‘Request for Comment on Enhancements to
Post-Trade Transaction Data Disseminated Through
a New Central Transparency Platform,’’ MSRB
Notice 2014–14 (August 31, 2014).
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sufficient time to make any required
changes in due course without causing
adverse 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 January 17, 2013, the MSRB
provided background information on
the MSRB’s initiative under the LongRange Plan 12 to refresh the technology
of RTRS and sought public comment on
the appropriate standard for ‘‘real-time’’
reporting and dissemination of
transaction price and related
information, as well as on baseline
technology, processing and data
protocols for post-trade transaction
information (‘‘January Release’’).13 On
July 31, 2013, the MSRB sought public
comment on enhancements to data
elements disseminated publicly through
RTRS (‘‘July Release’’).14 Based upon
the comments received in response to
the January and July Releases, the MSRB
identified specific enhancements to
RTRS and solicited on August 13, 2014
public input on the specific components
of the post-trade reporting and public
dissemination enhancements as well as
on the likely benefits and burdens
associated with the potential
enhancements (‘‘August Release’’).15
The MSRB received comments on the
January Release from fifteen
commenters,16 on the July Release from
12 See ‘‘MSRB Publishes Long-Range Market
Transparency Plan,’’ MSRB Notice 2012–06
(February 23, 2012).
13 See ‘‘Request for Comment on More
Contemporaneous Trade Price Information Through
a New Central Transparency Platform,’’ MSRB
Notice 2013–02 (January 17, 2013).
14 See ‘‘Concept Release on Pre-Trade and PostTrade Pricing Data Dissemination Through a New
Central Transparency Platform,’’ MSRB Notice
2013–14 (July 31, 2013).
15 See ‘‘Request for Comment on Enhancements to
Post-Trade Transaction Data Disseminated Through
a New Central Transparency Platform,’’ MSRB
Notice 2014–14 (August 13, 2014).
16 Comments were received on the January
Release from Barclays Capital Inc.: Letter from Scott
Coya, Director, Municipal Compliance, dated March
15, 2013 (‘‘Barclays’’); Bond Dealers of America:
Letter from Michael Nicholas, Chief Executive
Officer, dated March 15, 2013 (‘‘BDA–1’’); Charles
Schwab & Co. Inc.: Letter from Michael P. Moran,
Vice President, Fixed Income Compliance, dated
March 15, 2013 (‘‘Schwab’’); Eastern Bank: Email
from James N. Fox, SVP and Managing Director,
dated March 15, 2013 (‘‘Eastern’’); Financial
Information Forum: Letter from Arsalan Shahid,
Program Director, dated March 15, 2013 (‘‘FIF–1’’);
Financial Services Institute: Letter from David T.
Bellaire, Executive Vice President and General
Counsel, dated March 15, 2013 (‘‘FSI’’); Frost Bank:
Letter from Robert N. Jacobs, Assistant Vice
President/Compliance Officer, dated March 11,
2013 (‘‘Frost’’); Investment Company Institute:
Letter from Dorothy Donohue, Deputy General
Counsel-Securities Regulation, dated March 15,
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nine commenters,17 and on the August
Release from seven commenters.18 The
portions of these notices relating to the
proposed rule change, the comments
received in response to such portions,
and the MSRB’s responses are discussed
below.19
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Expanding the Application of Existing
List Offering Price and RTRS Takedown
Indicators
The July Release solicited input on
whether changes to the List Offering
Price Transaction and RTRS Takedown
Transaction indicators would be
warranted given evolutions in market
2013 (‘‘ICI’’); J.W. Korth & Company LP: Email from
James Korth dated March 14, 2013 (‘‘JWKorth’’);
R.W. Smith & Associates, Inc.: Email from Paige
Pierce dated March 20, 2013 (‘‘RWSmith–1’’);
Securities Industry and Financial Markets
Association: Letter from Leslie M. Norwood,
Managing Director and Associate General Counsel,
dated March 15, 2013 (‘‘SIFMA–1’’); Seidel & Shaw,
LLC: Letter from Thomas W. Shaw, President, dated
March 15, 2013 (‘‘Seidel’’); Standish Mellon Asset
Management Company LLC: Email from Daniel
Rabasco dated March 15, 2013 (‘‘Standish’’); TMC
Bonds, L.L.C.: Letter from Thomas S. Vales, Chief
Executive Officer, dated March 15, 2013
(‘‘TMCBonds’’); and Tradition Asiel Securities, Inc.:
Letter from Eric M. Earnhardt, Chief Compliance
Officer, dated March 19, 2013 (‘‘TASI’’).
17 Comments were received on the July Release
from Bond Dealers of America: Letter from Michael
Nicholas, Chief Executive Officer, dated November
1, 2013 (‘‘BDA–2’’); Corporate Treasury Investment
Consulting LLC: Letter from Mark O. Conner,
Principal, dated August 16, 2013 (‘‘CTIC’’);
Financial Information Forum: Letter from Manisha
Kimmel, Executive Director, dated November 1,
2013 (‘‘FIF–2’’); Interactive Data Corporation: Letter
from Mark Hepsworth, President, Interactive Data
Pricing and Reference Data, dated November 1,
2013 (‘‘IDC’’); Leonard, Jack: Letter dated August 1,
2013 (‘‘Mr. Leonard’’); Long, Cate: Email dated
November 1, 2013 (‘‘Ms. Long’’); Sayer, Steven:
Email dated November 3, 2013 (‘‘Mr. Sayer’’);
Securities Industry and Financial Markets
Association: Letter from Leslie M. Norwood,
Managing Director and Associate General Counsel,
dated November 1, 2013 (‘‘SIFMA–2’’); and Wells
Fargo Advisors, LLC: Letter from Robert J.McCarthy,
Director of Regulatory Policy, dated November 1,
2013 (‘‘Wells Fargo’’).
18 Comments were received on the August Release
from Bond Dealers of America: Letter from Michael
Nicholas, Chief Executive Officer, dated September
26, 2014 (‘‘BDA–3’’); Financial Information Forum:
Letter from Darren Wasney, Program Manager,
dated September 19, 2014 (‘‘FIF–3’’); Income
Securities Advisor Inc.: Email from Richard
Lehmann dated August 26, 2014 (‘‘ISA’’); Murez,
Herbert: Email dated August 13, 2014 (‘‘Mr.
Murez’’); RW Smith & Associates, LLC: Email from
Paige W. Pierce, President and Chief Executive
Officer, dated September 26, 2014 (‘‘RWSmith–2’’);
Securities Industry and Financial Markets
Association: Letter from Leslie M. Norwood,
Managing Director and Associate General Counsel,
dated September 25, 2014 (‘‘SIFMA–3’’); and Trigo,
Loren: Email dated August 13, 2014 (‘‘Trigo’’).
19 The January, July and August Releases
contemplated additional enhancements to RTRS as
well as the establishment of a new program for pretrade transparency. Comments in response to those
items are not addressed in this proposed rule
change but would be addressed in any future
rulemaking on those items that the MSRB
determines to undertake.
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practices and the information publicly
available through the EMMA Web site.
The August Release proposed
expanding the application of the List
Offering Price Transaction and RTRS
Takedown Transaction indicators to
include scenarios where: (i) Dealers
have entered into long-term marketing
arrangements with other dealers that
serve in the syndicate or selling group
for purchasing and re-selling new issue
securities (‘‘distribution participant
dealers’’); (ii) takedown transactions are
not at a discount from the list offering
price; and (iii) offerings that occur over
a number of days with different list
offering prices set each day.
FIF–3 and SIFMA–3 stated support
for expanding the application of the List
Offering Price Transaction and RTRS
Takedown Transaction indicators. With
respect to including distribution
participant dealers in the definition of
which dealers must use the indicator,
SIFMA–3 noted that these dealers
perform ‘‘a similar function to a selling
group member.’’ Further, in response to
whether takedown transactions that are
not at a discount from the list offering
price, which would occur in the case of
a group net or net designated order
arrangement, should be included in the
definition of an RTRS Takedown
Transaction, FIF–3 and SIFMA–3
indicated support and SIFMA–3 stated
that this change ‘‘will conform the rule
to widespread industry practice’’
although FIF–3 noted that they ‘‘see this
happening frequently in the corporate
bond market but infrequently in the
municipal bond market.’’
Comments were mixed in response to
whether offerings that occur over a
number of days with different list
offering prices set each day should be
included in the List Offering Price
Transaction and RTRS Takedown
Transaction indicators. FIF–3 offered
support for this change and stated that
it ‘‘agree[s] that if the distribution
occurs on days that are not the first day
of trading of a new issue, the
distribution should still be reported as
the list price.’’ SIFMA–3 did not
support this change and stated that this
‘‘change would be confusing for
investors.’’
After careful consideration of the
comments received, and given the
absence of evidence of widespread use
of offerings occurring over a number of
days with different list offering prices
set each day, the MSRB has determined
not to propose to expand the application
of the indicator to address this scenario
at this time, although the MSRB may
revisit this issue if these types of
offerings become more frequent.
PO 00000
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16469
Eliminating the Requirement for Dealers
To Report Yield on Customer Trade
Reports
The July and August Releases
proposed to eliminate the requirement
for dealers to include yield on customer
trade reports and, instead, enable the
MSRB to calculate and disseminate
yield on customer trades. The August
Release solicited input on whether this
change would alleviate operational
concerns cited by dealers in connection
with reporting certain ‘‘away from
market’’ trade reports.
BDA–3, FIF–2, FIF–3, IDC, SIFMA–2
and SIFMA–3 supported eliminating the
requirement to include yield on
customer trade reports. Eliminating this
requirement would make the MSRB’s
RTRS yield reporting requirements
consistent with those established by
Financial Industry Regulatory Authority
(‘‘FINRA’’) for corporate bond
transactions and reduce the amount of
error feedback returned to dealers when
minor discrepancies arise. BDA–3 stated
that ‘‘MSRB’s calculation of yields
would avoid differences in yield
calculations across dealers due to
security master differences’’ and
‘‘[c]ustomers and dealers would also
benefit from the improved consistency
in the calculation of yield to worst.’’
SIFMA–3 noted that the ‘‘elimination of
the broker-dealer requirement to report
yield on customer trade reports does
also alleviate some operational concerns
in connection with reporting certain
‘away from market’ trade reports, such
as transactions arising from customer
repurchase agreements.’’
FIF–3, SIFMA–2 and SIFMA–3 cited
a concern related to potential
differences in the yield calculated by
MSRB and displayed on EMMA and the
yield calculated by dealers and
displayed on customer confirmations.
FIF–3 stated that the MSRB should
‘‘consider the impact of discrepancies
between the MSRB’s calculations and
dealer-calculated yield to worst which
will appear on a customer’s confirm’’
and recommends that the MSRB
‘‘[provide] guidance for cases where
there are discrepancies between the
MSRB’s calculations and dealercalculated yield to worst on a
customer’s confirm.’’ SIFMA–2
observed that dealers have the
responsibility to report yield to
customers on trade confirmations and
that, due to the complicated nature of
some redemption provisions, the dealercalculated yield and the MSRBcalculated yield may not always match
precisely. FIF–2 and IDC suggested that
the display of the date to which this
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yield-to-worst calculation is determined
would be helpful.
After carefully considering
commenters’ concerns, the MSRB
believes potential confusion would be
addressed by additionally displaying on
EMMA the calculation method (yield to
call or maturity) and, for yield to call,
the call date and price used. Under this
approach, any differences between
dealer and MSRB calculations could be
understood by viewing the inputs the
MSRB used in its calculation.
Establishing a New Indicator for
Customer Trades Involving NonTransaction-Based Compensation
Arrangements
The July and August Releases
proposed the establishment of a new
indicator to distinguish in the price
transparency data between customer
transactions that do not include a dealer
compensation component and those that
include a mark-up or mark-down or a
commission.
BDA–3, FIF–2, FIF–3, Ms. Long,
SIFMA–2, SIFMA–3, and Wells Fargo
favored the addition of an indicator for
identifying transactions that are not
inclusive of a compensation component.
SIFMA–2, however, opposed requiring
the reporting of the details of the nontransaction based compensation
arrangement. BDA–3 stated that a new
indicator ‘‘would provide the users of
trade transparency products with
information that could explain certain
variations in trade prices and assist in
best execution determinations.’’
SIFMA–3 suggested that, if the MSRB
publicly disseminates the existing
agency or principal trade indicator
currently collected, this would
accomplish the same benefit and also
stated that the MSRB should not
consider collecting information on the
nature of alternative compensation
beyond an indicator as such information
would be burdensome to report.
The MSRB does not believe that
SIFMA–3’s suggestion that
disseminating the existing agency or
principal trade indicator currently
collected would help distinguish in the
price transparency data customer
transactions that do not include a dealer
compensation component, particularly
because the MSRB understands that
both agency and principal transactions
can occur under current market
practices without a dealer compensation
component. With respect to SIFMA–2’s
view that the MSRB should not consider
collecting information on the nature of
alternative compensation, the MSRB
notes that this was not contemplated in
the July or August Release and is not
part of the proposed rule change.
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20:59 Mar 26, 2015
Jkt 235001
Establishing a New Indicator for ATS
Transactions
The July and August Releases
proposed adding an indicator to identify
transactions executed using the services
of an ATS, which indicator would be
included in the information
disseminated publicly. The August
Release also proposed that, in instances
where an ATS does not take a principal
position between two dealers, each
dealer would be required to report the
identity of the ATS employed.
In response to the July Release, Ms.
Long supported the addition of an ATS
indicator on trades, and stated that the
specific ATS used should be identified,
initially for surveillance purposes and
potentially for future public
dissemination. FIF–2 noted operational
burdens associated with identifying
trades executed using the services of an
ATS, particularly in instances where the
ATS does not act as the counter-party to
the trade. SIFMA–2 questioned the
‘‘tangible transparency benefits to the
market’’ of including an ATS indicator.
In response to the August Release,
SIFMA–3 and FIF–3 noted that this
indicator would result in a cost to
dealers to implement. SIFMA–3 stated
that it ‘‘recognizes that the MSRB has a
legitimate interest in determining ATS
participation in the market, and likely
has no other way to get this information
on a real-time basis.’’ FIF–3 noted that
FINRA is pursuing the establishment of
a similar ATS indicator for corporate
bond trade reports.
In response to a potential requirement
that dealers also would need to identify
in some cases the ATS employed,
SIFMA–3 and FIF–3 suggested that this
component would add operational
complexity and compliance costs to the
requirement. SIFMA–3 stated that
‘‘[a]lthough flagging these trades would
be a significant operational and
administrative burden, the burden
would be minimized for the brokerdealer community if the result was a
mere change in an ‘M code’ ’’ (which is
the change that would be made to
simply identify that an ATS was
employed, exclusive of the ATS’s
identity). FIF–3 stated in response to the
proposed requirement to identify the
ATS employed that they ‘‘believe this
would be challenging to implement.’’
From a market structure perspective,
the MSRB believes that it is important
to know the extent to which ATSs are
employed for inter-dealer transactions
as such information could inform future
system development, research and
rulemaking initiatives. While also
having the identity of the ATS in
instances where the ATS does not take
PO 00000
Frm 00112
Fmt 4703
Sfmt 4703
a principal position between two
dealers would increase the usefulness of
the ATS indicator, the MSRB is
sensitive to the burden such a
requirement would impose, particularly
given the future potential establishment
by the MSRB of a pre-trade transparency
system. The MSRB notes that under a
comprehensive pre-trade transparency
system, it is anticipated that the identity
of each ATS would be known and the
extent to which each is used in the
municipal market would therefore be
quantifiable. Accordingly, the MSRB
believes that proceeding with the
establishment of an ATS indicator,
which the MSRB plans to implement
utilizing the existing special condition
indicator (the ‘‘M code’’) field in RTRS,
is appropriate. The MSRB, however, in
acknowledgement of the burdens
identified by commenters, has not
included in this proposed rule change a
requirement to report the identity of the
ATS that was used.
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 rule-comments@
sec.gov. Please include File Number SR–
MSRB–2015–02 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549.
All submissions should refer to File
Number SR–MSRB–2015–02. This file
number should be included on the
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Federal Register / Vol. 80, No. 59 / Friday, March 27, 2015 / Notices
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 principal
office of the MSRB. 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–
2015–02 and should be submitted on or
before April 17, 2015.
For the Commission, pursuant to delegated
authority.20
Brent J. Fields,
Secretary.
[FR Doc. 2015–06993 Filed 3–26–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–74563; File No. SR–ICC–
2015–004]
Self-Regulatory Organizations; ICE
Clear Credit LLC; Notice of Filing of
Proposed Rule Change Relating to
Physical Settlement of CDS Contracts
mstockstill on DSK4VPTVN1PROD with NOTICES
March 23, 2015.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on March 11,
2015, ICE Clear Credit LLC (‘‘ICC’’ or the
‘‘clearinghouse’’) 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
20 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
VerDate Sep<11>2014
20:59 Mar 26, 2015
Jkt 235001
primarily by ICC. 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 purpose of the proposed rule
change is to amend ICC rules to modify
the terms and conditions for physical
settlement of cleared CDS Contracts,
and to adopt certain new delivery
procedures relating to physical
settlement.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, ICC
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. ICC has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of these statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
ICC submits proposed amendments to
the ICC Clearing Rules (‘‘ICC Rules’’)
relating to physical settlement of CDS
Contracts. Upon the occurrence of a
credit event under a cleared CDS
Contract, the contract is typically settled
in cash in accordance with the terms of
the ICC Rules, which incorporate the
applicable ISDA Credit Derivatives
Definitions (the ‘‘ISDA Definitions’’)
and the market-standard credit default
swap auction methodology for
determining the cash settlement price.
However, in certain circumstances, such
as where the Credit Derivatives
Determinations Committee decides not
to hold a cash settlement auction for a
particular credit event, or such an
auction is cancelled under the terms of
the auction methodology (including
because of a failure to determine the
auction settlement price), the CDS
Contracts provide for a fallback
settlement method of physical
settlement. Under physical settlement of
a CDS contract generally, the protection
buyer will be entitled to deliver one or
more qualifying deliverable obligations
to the protection seller, in which case
the protection seller will be required to
pay the protection buyer a defined
physical settlement amount. Under the
current ICC Rules, if physical settlement
PO 00000
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Fmt 4703
Sfmt 4703
16471
applies,3 the clearinghouse will match
clearing participants (‘‘Participants’’)
that are protection buyers with
Participants that are protection sellers in
the relevant contract, and the two
Participants will be responsible for
effecting physical settlement between
them. ICC does not itself perform or
guarantee performance of physical
settlement between the matched
Participants. Once matching occurs, the
contract is purely a bilateral contract
between the matched Participants, and
the clearinghouse has no further rights
or obligations with respect to the
contract. ICC does, however, collect and
hold physical settlement margin as
collateral agent on behalf of the
protection buyer to secure the
protection seller’s obligations to the
protection buyer under physical
settlement.
At the request of its Participants, and
following extensive consultation with
them, ICC proposes to amend the ICC
Rules relating to physical settlement
such that the clearinghouse will be
responsible for financial performance of
physical settlement. ICC understands
that Participants and other market
participants view the current approach,
in which cash settlement of credit
events is guaranteed by the
clearinghouse but physical settlement is
not, as creating a potentially anomalous
result in the unlikely case that physical
settlement may apply. The application
of physical settlement would be a
circumstance that is generally not
within any Participant’s control, and
under the current rules may expose
Participants to a significantly different
credit risk profile than under cash
settlement (where the Participant is
exposed to the credit of the
clearinghouse). In light of these
discussions, ICC has determined that it
is appropriate to extend the clearing
guarantee to the financial performance
of physical settlement. ICC notes that
under the amended approach, it would
still require payments and deliveries in
the ordinary course under physical
settlement to be made directly between
the matched buying Participant and
selling Participant, with the
clearinghouse only being obligated to
make direct payments in the case of
certain defined settlement failure
scenarios. ICC believes that this
proposed rule change will further the
general policy goals of central clearing
for CDS transactions, and is consistent
with the clearinghouse’s financial
3 ICC notes that to date, physical settlement has
not been necessary for any of the CDS Contracts
cleared by ICC.
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Agencies
[Federal Register Volume 80, Number 59 (Friday, March 27, 2015)]
[Notices]
[Pages 16466-16471]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2015-06993]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-74564; File No. SR-MSRB-2015-02]
Self-Regulatory Organizations; Municipal Securities Rulemaking
Board; Notice of Filing of a Proposed Rule Change Consisting of
Proposed Amendments to the MSRB Rule G-14 RTRS Procedures, and the
Real-Time Transaction Reporting System and Subscription Service
March 23, 2015.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(the ``Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is hereby given
that on March 19, 2015, the Municipal Securities Rulemaking Board (the
``MSRB'' or ``Board'') filed with the Securities and Exchange
Commission (the ``SEC'' or ``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.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
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
consisting of proposed amendments to the MSRB Rule G-14 RTRS
Procedures, and the Real-Time Transaction Reporting System and
subscription service (collectively, the ``proposed rule change''). The
MSRB is proposing that the effective date for the proposed rule change
be no later than May 23, 2016 and announced by the MSRB in a notice
published on the MSRB Web site no later than sixty (60) days prior to
the effective date.
The text of the proposed rule change is available on the MSRB's Web
site at www.msrb.org/Rules-and-Interpretations/SEC-Filings/2015-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
MSRB Rule G-14, on reports of sales or purchases, requires brokers,
dealers and municipal securities dealers (collectively ``dealers'') to
report all executed transactions in municipal securities to RTRS within
15 minutes of the time of trade, with limited exceptions.\3\ RTRS
serves the dual objectives of price transparency and market
surveillance. Because a comprehensive database of transactions is
needed for the surveillance function of RTRS, Rule G-14, with limited
exceptions, requires dealers to report all of their purchase-sale
transactions to RTRS, not only those that qualify for public
dissemination to serve the transparency function of the system.\4\ The
MSRB makes transaction data available to the general public through the
Electronic Municipal Market Access (``EMMA'') Web site at no cost, and
disseminates such data through paid subscription services to market
data vendors, institutional market participants and others that
subscribe to the data feed.
---------------------------------------------------------------------------
\3\ Transactions in securities without CUSIP numbers, in
municipal fund securities, and certain inter-dealer securities
movements not eligible for comparison through a clearing agency are
the only transactions exempt from the reporting requirements of Rule
G-14.
\4\ In this respect, RTRS serves as an audit trail for municipal
securities trading, with the exception of certain internal movements
of securities within dealers that currently are not required to be
reported, customer identifications, and other related specific items
of information. Compare Consolidated Audit Trail, Release No. 34-
67457 (July 18, 2012), 77 FR 45722 (August 1, 2012), File No. S7-11-
10.
---------------------------------------------------------------------------
As more fully described below, the proposed rule change would
enhance the post-trade price transparency information provided through
RTRS by:
Expanding the application of the existing list offering
price and takedown indicator to cases involving distribution
participant dealers and takedown transactions that are not at a
discount from the list offering price;
eliminating the requirement for dealers to report yield on
customer trade reports and, instead, enabling the MSRB to calculate and
disseminate yield on customer trades;
establishing a new indicator for customer trades involving
non-transaction-based compensation arrangements; and
establishing a new indicator for alternative trading
system (``ATS'') transactions.
Expanding the Application of Existing List Offering Price and RTRS
Takedown Indicator
Transaction reporting procedures require dealers that are part of
the underwriting group for a new issuance of municipal securities to
include an indicator on trade reports, which indicator is disseminated
to the public, for transactions executed on the first day of trading in
a new issue with prices set under an offering agreement for the new
issue. These transactions include sales to customers by a sole
underwriter, syndicate manager, syndicate member or selling group
member at the published list offering price for the security (``List
Offering Price Transaction'') or by a sole underwriter or syndicate
manager to a syndicate or selling group member at a discount from the
published list offering price for the security (``RTRS Takedown
Transaction''). Such trade reports are provided an end-of-day exception
from Rule G-14's general 15-minute reporting requirement.
Since the introduction of the List Offering Price Transaction
indicator in 2005 and RTRS Takedown Transaction indicator in 2007,
certain market practices in this area have evolved. First, outside of
traditional underwriting syndicates or selling groups, some dealers
have entered into long-term marketing arrangements with other dealers
that serve in the syndicate or selling group relating to purchases and
re-sales of new issue securities
[[Page 16467]]
(``distribution participant dealers''). The MSRB understands that these
distribution participant dealers agree to execute transactions with
customers at the published list offering prices. Accordingly, the
proposed rule change would expand the application of List Offering
Price Transaction and RTRS Takedown Transaction indicators to sale
transactions by distribution participant dealers to customers at the
list offering price and sale transactions by a sole underwriter or
syndicate manager to distribution participant dealers.
A second evolution in market practice in this area relates to the
prices at which takedown transactions occur. The RTRS Takedown
Transaction indicator currently is limited to inter-dealer transactions
occurring at a discount from the published list offering price. The
MSRB understands that, in some new issues, transactions between a sole
underwriter or syndicate manager to a syndicate member, selling group
member or distribution participant dealer are not executed at a
discount from the published list offering price or at the full takedown
amount. This typically occurs in the case of group net or net
designated order arrangements. The proposed rule change expands the
application of the RTRS Takedown Transaction indicator to any sale
transaction by a sole underwriter or syndicate manager to a syndicate
member, selling group member or distribution participant dealer on the
first day of trading in the new issue.
Eliminating the Requirement for Dealers To Report Yield on Customer
Trade Reports
Transaction reporting procedures currently require dealers to
include on most reports of customer transactions to RTRS both a dollar
price and yield.\5\ The yield required to be reported to RTRS for
customer trades is consistent with the yield required to be displayed
on a customer confirmation under Rule G-15(a), which requires that
yield be computed to the lower of an ``in whole'' call or maturity,
subject to certain requirements set forth in the rule for specific
special situations (generally referred to as the ``yield to worst'').
Rule G-15(a) requires the confirmation to include the date to which
yield is calculated if that date is other than the nominal maturity
date, and also requires the confirmation for a transaction effected
based on a yield other than yield to worst to include both yields.
Since April 30, 2012, the MSRB has calculated and included in
disseminated RTRS information the yield on inter-dealer trades computed
in the same manner as required for customer trades.\6\
---------------------------------------------------------------------------
\5\ For inter-dealer transactions, dealers report the dollar
price at which the transaction was effected and the MSRB calculates
and includes in disseminated information the corresponding yield.
\6\ See ``SEC Approves Amendments to MSRB Rule G-14, on Reports
of Sales or Purchases, Including Rule G-14 RTRS Procedures, and
Amendments to the Real-Time Transaction Reporting System,'' MSRB
Notice 2012-15 (March 21, 2012).
---------------------------------------------------------------------------
The proposed rule change would eliminate the requirement for
dealers to include yield on customer trade reports.\7\ Consistent with
the manner in which the MSRB calculates and includes in disseminated
RTRS information yield on inter-dealer trades, the MSRB would calculate
and disseminate yield on customer trade reports.\8\ This would remove
one aspect of a dealer's burden in reporting customer transactions to
the MSRB in compliance with MSRB Rule G-14 \9\ and ensure that the
calculation and dissemination of yields for both inter-dealer and
customer transactions are consistent.
---------------------------------------------------------------------------
\7\ This change is anticipated to also have the benefit of
alleviating particular operational concerns cited by dealers in
connection with reporting certain ``away from market'' trade
reports.
\8\ Note that dealers would continue to be able to report that a
when, as and if issued transaction was executed on the basis of
yield in the event that the settlement date is not known at the time
the trade is executed, which prevents an accurate calculation of the
corresponding dollar price to be performed.
\9\ RTRS currently performs price/yield calculations, compares
RTRS-computed values to dealer-reported values, and returns errors
to dealers when discrepancies are found. This results in dealers
researching and responding to such errors which, in many cases, are
the results of differences in vendor-provided security descriptive
information utilized by dealers and RTRS. By removing the
requirement to include yield on customer trade reports, the proposed
rule change would have the effect of eliminating these errors. In
addition, in the case of transactions arising from customer
repurchase agreements, the proposed rule change would eliminate the
burden on dealers of calculating for trade reporting purposes a
yield consistent with the requirements of Rule G-15(a), which the
MSRB understands presents operational challenges given that this
represents a different calculation from the calculation used to
determine the yield resulting from the terms of the repurchase
agreement.
---------------------------------------------------------------------------
Establishing a New Indicator for Customer Trades Involving Non-
Transaction-Based Compensation Arrangements
For principal transactions by dealers, the trade price reported to
and publicly disseminated by the MSRB includes all aspects of the
price, including any mark-up or mark-down that compensates the dealer
for executing the transaction. In agency transactions, dealers are
required to report to the MSRB both the price of the security and the
commission charged to the customer. The prices publicly disseminated
for agency transactions incorporate the reported commission to provide
for comparability with the prices for principal trades. However,
dealers effecting transactions with customers as part of an arrangement
that does not provide for dealer compensation to be paid on a
transaction-based basis, such as in certain wrap fee arrangements,
report to the MSRB transaction prices that do not include a
compensation component.
To distinguish in the transaction information disseminated publicly
between customer transactions that do not include a dealer compensation
component and those that include a mark-up or mark-down or a
commission, the proposed rule change would require dealers to include a
new indicator on their trade reports that would be disseminated
publicly. This would improve the usefulness of the transaction
information disseminated publicly by enabling users of the price
transparency information to distinguish those customer transactions
that do not include a dealer compensation component.
Establishing a New Indicator for ATS Transactions
Dealers may use a variety of means to transact in municipal
securities, including broker's brokers or ATSs as well as traditional
direct transactions with a known counterparty. The MSRB currently
identifies all transactions reported as having been executed by a
broker's broker in the transaction information disseminated publicly.
This identifier is applied based on the broker's broker informing the
MSRB that it acts in such capacity. The MSRB does not currently
identify trades as having been executed through an ATS.
To better ascertain the extent to which ATSs are used in the
municipal market and to indicate to market participants on disseminated
transaction information that an ATS was used, the proposed rule change
would establish an additional new indicator. For those ATSs that take a
principal position between a buyer and seller, the ATS and the dealers
that transact with the ATS would be required to include the ATS
indicator on trade reports. In instances where an ATS connects a buyer
and seller but does not take a principal or agency position between
those parties and therefore does not have a transaction reporting
requirement under MSRB rules, the dealers that transact with each other
as a result of using the services of the ATS would be required to
include the ATS indicator on their trade reports. In all cases, the ATS
indicator would be included on transaction information
[[Page 16468]]
disseminated publicly. Identifying in disseminated transaction
information that an ATS was employed should facilitate higher quality
research and analysis of market structure by providing information
about the extent to which ATSs are used and should complement the
existing indicator disseminated for transactions involving a broker's
broker.
Effective Date of the Proposed Rule Change
To provide time for the MSRB to undertake the programming changes
to implement the proposed rule change, as well as to provide an
adequate testing period for dealers and subscribers that interface with
RTRS, the MSRB is proposing an effective date for the proposed rule
change to be announced by the MSRB in a notice published on the MSRB
Web site, which date shall be no later than May 23, 2016 and shall be
announced no later than sixty (60) days prior to the effective date.
2. Statutory Basis
The MSRB believes that the proposed rule change is consistent with
Section 15B(b)(2)(C) of the 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.
The MSRB believes that the proposed rule change is consistent with
the Act. The MSRB believes that the proposed rule change would remove
impediments to and perfect the mechanism of a free and open market in
municipal securities by increasing the quality and usefulness of the
post-trade price transparency information provided through RTRS. The
MSRB believes the expansion of the application of the existing list
offering price and takedown indicator to cases involving distribution
participant dealers and takedown transactions that are not at a
discount from the list offering price, establishment of a new indicator
for customer trades involving non-transaction-based compensation
arrangements, and establishment of a new indicator for ATS transactions
would enable users of the post-trade price transparency information
provided through RTRS to better understand the pricing of certain
transactions as well as how such transactions were executed. As
previously noted, identifying in disseminated transaction information
that an ATS was employed should facilitate higher quality research and
analysis of market structure by providing information about the extent
to which ATSs are used and should complement the existing indicator
disseminated for transactions involving a broker's broker. Accordingly,
the proposed rule 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 would impose any
burden on competition not necessary or appropriate in furtherance of
the purposes of the Act. Information disseminated by RTRS is available
to all persons on an equal and non-discriminatory basis. 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 providing value-added services and products to
third parties based on such information on terms determined by each
subscriber.\10\
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\10\ 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.
---------------------------------------------------------------------------
The MSRB recognizes that the proposed rule change would impose a
burden on dealers and subscribers that interface with RTRS to comply
with the reporting and dissemination of the new indicators that would
be required by the proposed rule change. The MSRB solicited and
received comment on several potential burdens of the proposed rule
change and the specific comments and responses thereto are discussed
below.\11\ The MSRB plans to provide a six month testing period in
advance of the effective date. The MSRB believes that a six month
testing period in advance of the effective date would provide dealers
and subscribers with sufficient time to make any required changes in
due course without causing adverse disruptions to their information
technology plans or budgets.
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\11\ See ``Request for Comment on Enhancements to Post-Trade
Transaction Data Disseminated Through a New Central Transparency
Platform,'' MSRB Notice 2014-14 (August 31, 2014).
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C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
On January 17, 2013, the MSRB provided background information on
the MSRB's initiative under the Long-Range Plan \12\ to refresh the
technology of RTRS and sought public comment on the appropriate
standard for ``real-time'' reporting and dissemination of transaction
price and related information, as well as on baseline technology,
processing and data protocols for post-trade transaction information
(``January Release'').\13\ On July 31, 2013, the MSRB sought public
comment on enhancements to data elements disseminated publicly through
RTRS (``July Release'').\14\ Based upon the comments received in
response to the January and July Releases, the MSRB identified specific
enhancements to RTRS and solicited on August 13, 2014 public input on
the specific components of the post-trade reporting and public
dissemination enhancements as well as on the likely benefits and
burdens associated with the potential enhancements (``August
Release'').\15\ The MSRB received comments on the January Release from
fifteen commenters,\16\ on the July Release from
[[Page 16469]]
nine commenters,\17\ and on the August Release from seven
commenters.\18\ The portions of these notices relating to the proposed
rule change, the comments received in response to such portions, and
the MSRB's responses are discussed below.\19\
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\12\ See ``MSRB Publishes Long-Range Market Transparency Plan,''
MSRB Notice 2012-06 (February 23, 2012).
\13\ See ``Request for Comment on More Contemporaneous Trade
Price Information Through a New Central Transparency Platform,''
MSRB Notice 2013-02 (January 17, 2013).
\14\ See ``Concept Release on Pre-Trade and Post-Trade Pricing
Data Dissemination Through a New Central Transparency Platform,''
MSRB Notice 2013-14 (July 31, 2013).
\15\ See ``Request for Comment on Enhancements to Post-Trade
Transaction Data Disseminated Through a New Central Transparency
Platform,'' MSRB Notice 2014-14 (August 13, 2014).
\16\ Comments were received on the January Release from Barclays
Capital Inc.: Letter from Scott Coya, Director, Municipal
Compliance, dated March 15, 2013 (``Barclays''); Bond Dealers of
America: Letter from Michael Nicholas, Chief Executive Officer,
dated March 15, 2013 (``BDA-1''); Charles Schwab & Co. Inc.: Letter
from Michael P. Moran, Vice President, Fixed Income Compliance,
dated March 15, 2013 (``Schwab''); Eastern Bank: Email from James N.
Fox, SVP and Managing Director, dated March 15, 2013 (``Eastern'');
Financial Information Forum: Letter from Arsalan Shahid, Program
Director, dated March 15, 2013 (``FIF-1''); Financial Services
Institute: Letter from David T. Bellaire, Executive Vice President
and General Counsel, dated March 15, 2013 (``FSI''); Frost Bank:
Letter from Robert N. Jacobs, Assistant Vice President/Compliance
Officer, dated March 11, 2013 (``Frost''); Investment Company
Institute: Letter from Dorothy Donohue, Deputy General Counsel-
Securities Regulation, dated March 15, 2013 (``ICI''); J.W. Korth &
Company LP: Email from James Korth dated March 14, 2013
(``JWKorth''); R.W. Smith & Associates, Inc.: Email from Paige
Pierce dated March 20, 2013 (``RWSmith-1''); Securities Industry and
Financial Markets Association: Letter from Leslie M. Norwood,
Managing Director and Associate General Counsel, dated March 15,
2013 (``SIFMA-1''); Seidel & Shaw, LLC: Letter from Thomas W. Shaw,
President, dated March 15, 2013 (``Seidel''); Standish Mellon Asset
Management Company LLC: Email from Daniel Rabasco dated March 15,
2013 (``Standish''); TMC Bonds, L.L.C.: Letter from Thomas S. Vales,
Chief Executive Officer, dated March 15, 2013 (``TMCBonds''); and
Tradition Asiel Securities, Inc.: Letter from Eric M. Earnhardt,
Chief Compliance Officer, dated March 19, 2013 (``TASI'').
\17\ Comments were received on the July Release from Bond
Dealers of America: Letter from Michael Nicholas, Chief Executive
Officer, dated November 1, 2013 (``BDA-2''); Corporate Treasury
Investment Consulting LLC: Letter from Mark O. Conner, Principal,
dated August 16, 2013 (``CTIC''); Financial Information Forum:
Letter from Manisha Kimmel, Executive Director, dated November 1,
2013 (``FIF-2''); Interactive Data Corporation: Letter from Mark
Hepsworth, President, Interactive Data Pricing and Reference Data,
dated November 1, 2013 (``IDC''); Leonard, Jack: Letter dated August
1, 2013 (``Mr. Leonard''); Long, Cate: Email dated November 1, 2013
(``Ms. Long''); Sayer, Steven: Email dated November 3, 2013 (``Mr.
Sayer''); Securities Industry and Financial Markets Association:
Letter from Leslie M. Norwood, Managing Director and Associate
General Counsel, dated November 1, 2013 (``SIFMA-2''); and Wells
Fargo Advisors, LLC: Letter from Robert J.McCarthy, Director of
Regulatory Policy, dated November 1, 2013 (``Wells Fargo'').
\18\ Comments were received on the August Release from Bond
Dealers of America: Letter from Michael Nicholas, Chief Executive
Officer, dated September 26, 2014 (``BDA-3''); Financial Information
Forum: Letter from Darren Wasney, Program Manager, dated September
19, 2014 (``FIF-3''); Income Securities Advisor Inc.: Email from
Richard Lehmann dated August 26, 2014 (``ISA''); Murez, Herbert:
Email dated August 13, 2014 (``Mr. Murez''); RW Smith & Associates,
LLC: Email from Paige W. Pierce, President and Chief Executive
Officer, dated September 26, 2014 (``RWSmith-2''); Securities
Industry and Financial Markets Association: Letter from Leslie M.
Norwood, Managing Director and Associate General Counsel, dated
September 25, 2014 (``SIFMA-3''); and Trigo, Loren: Email dated
August 13, 2014 (``Trigo'').
\19\ The January, July and August Releases contemplated
additional enhancements to RTRS as well as the establishment of a
new program for pre-trade transparency. Comments in response to
those items are not addressed in this proposed rule change but would
be addressed in any future rulemaking on those items that the MSRB
determines to undertake.
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Expanding the Application of Existing List Offering Price and RTRS
Takedown Indicators
The July Release solicited input on whether changes to the List
Offering Price Transaction and RTRS Takedown Transaction indicators
would be warranted given evolutions in market practices and the
information publicly available through the EMMA Web site. The August
Release proposed expanding the application of the List Offering Price
Transaction and RTRS Takedown Transaction indicators to include
scenarios where: (i) Dealers have entered into long-term marketing
arrangements with other dealers that serve in the syndicate or selling
group for purchasing and re-selling new issue securities
(``distribution participant dealers''); (ii) takedown transactions are
not at a discount from the list offering price; and (iii) offerings
that occur over a number of days with different list offering prices
set each day.
FIF-3 and SIFMA-3 stated support for expanding the application of
the List Offering Price Transaction and RTRS Takedown Transaction
indicators. With respect to including distribution participant dealers
in the definition of which dealers must use the indicator, SIFMA-3
noted that these dealers perform ``a similar function to a selling
group member.'' Further, in response to whether takedown transactions
that are not at a discount from the list offering price, which would
occur in the case of a group net or net designated order arrangement,
should be included in the definition of an RTRS Takedown Transaction,
FIF-3 and SIFMA-3 indicated support and SIFMA-3 stated that this change
``will conform the rule to widespread industry practice'' although FIF-
3 noted that they ``see this happening frequently in the corporate bond
market but infrequently in the municipal bond market.''
Comments were mixed in response to whether offerings that occur
over a number of days with different list offering prices set each day
should be included in the List Offering Price Transaction and RTRS
Takedown Transaction indicators. FIF-3 offered support for this change
and stated that it ``agree[s] that if the distribution occurs on days
that are not the first day of trading of a new issue, the distribution
should still be reported as the list price.'' SIFMA-3 did not support
this change and stated that this ``change would be confusing for
investors.''
After careful consideration of the comments received, and given the
absence of evidence of widespread use of offerings occurring over a
number of days with different list offering prices set each day, the
MSRB has determined not to propose to expand the application of the
indicator to address this scenario at this time, although the MSRB may
revisit this issue if these types of offerings become more frequent.
Eliminating the Requirement for Dealers To Report Yield on Customer
Trade Reports
The July and August Releases proposed to eliminate the requirement
for dealers to include yield on customer trade reports and, instead,
enable the MSRB to calculate and disseminate yield on customer trades.
The August Release solicited input on whether this change would
alleviate operational concerns cited by dealers in connection with
reporting certain ``away from market'' trade reports.
BDA-3, FIF-2, FIF-3, IDC, SIFMA-2 and SIFMA-3 supported eliminating
the requirement to include yield on customer trade reports. Eliminating
this requirement would make the MSRB's RTRS yield reporting
requirements consistent with those established by Financial Industry
Regulatory Authority (``FINRA'') for corporate bond transactions and
reduce the amount of error feedback returned to dealers when minor
discrepancies arise. BDA-3 stated that ``MSRB's calculation of yields
would avoid differences in yield calculations across dealers due to
security master differences'' and ``[c]ustomers and dealers would also
benefit from the improved consistency in the calculation of yield to
worst.'' SIFMA-3 noted that the ``elimination of the broker-dealer
requirement to report yield on customer trade reports does also
alleviate some operational concerns in connection with reporting
certain `away from market' trade reports, such as transactions arising
from customer repurchase agreements.''
FIF-3, SIFMA-2 and SIFMA-3 cited a concern related to potential
differences in the yield calculated by MSRB and displayed on EMMA and
the yield calculated by dealers and displayed on customer
confirmations. FIF-3 stated that the MSRB should ``consider the impact
of discrepancies between the MSRB's calculations and dealer-calculated
yield to worst which will appear on a customer's confirm'' and
recommends that the MSRB ``[provide] guidance for cases where there are
discrepancies between the MSRB's calculations and dealer-calculated
yield to worst on a customer's confirm.'' SIFMA-2 observed that dealers
have the responsibility to report yield to customers on trade
confirmations and that, due to the complicated nature of some
redemption provisions, the dealer-calculated yield and the MSRB-
calculated yield may not always match precisely. FIF-2 and IDC
suggested that the display of the date to which this
[[Page 16470]]
yield-to-worst calculation is determined would be helpful.
After carefully considering commenters' concerns, the MSRB believes
potential confusion would be addressed by additionally displaying on
EMMA the calculation method (yield to call or maturity) and, for yield
to call, the call date and price used. Under this approach, any
differences between dealer and MSRB calculations could be understood by
viewing the inputs the MSRB used in its calculation.
Establishing a New Indicator for Customer Trades Involving Non-
Transaction-Based Compensation Arrangements
The July and August Releases proposed the establishment of a new
indicator to distinguish in the price transparency data between
customer transactions that do not include a dealer compensation
component and those that include a mark-up or mark-down or a
commission.
BDA-3, FIF-2, FIF-3, Ms. Long, SIFMA-2, SIFMA-3, and Wells Fargo
favored the addition of an indicator for identifying transactions that
are not inclusive of a compensation component. SIFMA-2, however,
opposed requiring the reporting of the details of the non-transaction
based compensation arrangement. BDA-3 stated that a new indicator
``would provide the users of trade transparency products with
information that could explain certain variations in trade prices and
assist in best execution determinations.'' SIFMA-3 suggested that, if
the MSRB publicly disseminates the existing agency or principal trade
indicator currently collected, this would accomplish the same benefit
and also stated that the MSRB should not consider collecting
information on the nature of alternative compensation beyond an
indicator as such information would be burdensome to report.
The MSRB does not believe that SIFMA-3's suggestion that
disseminating the existing agency or principal trade indicator
currently collected would help distinguish in the price transparency
data customer transactions that do not include a dealer compensation
component, particularly because the MSRB understands that both agency
and principal transactions can occur under current market practices
without a dealer compensation component. With respect to SIFMA-2's view
that the MSRB should not consider collecting information on the nature
of alternative compensation, the MSRB notes that this was not
contemplated in the July or August Release and is not part of the
proposed rule change.
Establishing a New Indicator for ATS Transactions
The July and August Releases proposed adding an indicator to
identify transactions executed using the services of an ATS, which
indicator would be included in the information disseminated publicly.
The August Release also proposed that, in instances where an ATS does
not take a principal position between two dealers, each dealer would be
required to report the identity of the ATS employed.
In response to the July Release, Ms. Long supported the addition of
an ATS indicator on trades, and stated that the specific ATS used
should be identified, initially for surveillance purposes and
potentially for future public dissemination. FIF-2 noted operational
burdens associated with identifying trades executed using the services
of an ATS, particularly in instances where the ATS does not act as the
counter-party to the trade. SIFMA-2 questioned the ``tangible
transparency benefits to the market'' of including an ATS indicator. In
response to the August Release, SIFMA-3 and FIF-3 noted that this
indicator would result in a cost to dealers to implement. SIFMA-3
stated that it ``recognizes that the MSRB has a legitimate interest in
determining ATS participation in the market, and likely has no other
way to get this information on a real-time basis.'' FIF-3 noted that
FINRA is pursuing the establishment of a similar ATS indicator for
corporate bond trade reports.
In response to a potential requirement that dealers also would need
to identify in some cases the ATS employed, SIFMA-3 and FIF-3 suggested
that this component would add operational complexity and compliance
costs to the requirement. SIFMA-3 stated that ``[a]lthough flagging
these trades would be a significant operational and administrative
burden, the burden would be minimized for the broker-dealer community
if the result was a mere change in an `M code' '' (which is the change
that would be made to simply identify that an ATS was employed,
exclusive of the ATS's identity). FIF-3 stated in response to the
proposed requirement to identify the ATS employed that they ``believe
this would be challenging to implement.''
From a market structure perspective, the MSRB believes that it is
important to know the extent to which ATSs are employed for inter-
dealer transactions as such information could inform future system
development, research and rulemaking initiatives. While also having the
identity of the ATS in instances where the ATS does not take a
principal position between two dealers would increase the usefulness of
the ATS indicator, the MSRB is sensitive to the burden such a
requirement would impose, particularly given the future potential
establishment by the MSRB of a pre-trade transparency system. The MSRB
notes that under a comprehensive pre-trade transparency system, it is
anticipated that the identity of each ATS would be known and the extent
to which each is used in the municipal market would therefore be
quantifiable. Accordingly, the MSRB believes that proceeding with the
establishment of an ATS indicator, which the MSRB plans to implement
utilizing the existing special condition indicator (the ``M code'')
field in RTRS, is appropriate. The MSRB, however, in acknowledgement of
the burdens identified by commenters, has not included in this proposed
rule change a requirement to report the identity of the ATS that was
used.
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 rule-comments@sec.gov. Please include
File Number SR-MSRB-2015-02 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549.
All submissions should refer to File Number SR-MSRB-2015-02. This file
number should be included on the
[[Page 16471]]
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
principal office of the MSRB. 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-2015-02 and should be submitted on or before April
17, 2015.
For the Commission, pursuant to delegated authority.\20\
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\20\ 17 CFR 200.30-3(a)(12).
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Brent J. Fields,
Secretary.
[FR Doc. 2015-06993 Filed 3-26-15; 8:45 am]
BILLING CODE 8011-01-P