Self-Regulatory Organizations; Municipal Securities Rulemaking Board; Notice of Filing of a Proposed Rule Change To Amend Rule G-14 RTRS Procedures under MSRB Rule G-14 Regarding the Timing of Reporting Transactions in Municipal Securities to the MSRB and To Make a Related Amendment to Rule G-12, 26390-26399 [2025-11292]

Agencies

• SECURITIES AND EXCHANGE COMMISSION

[Federal Register Volume 90, Number 117 (Friday, June 20, 2025)]
[Notices]
[Pages 26390-26399]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-11292]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-103262; File No. SR-MSRB-2025-01]


Self-Regulatory Organizations; Municipal Securities Rulemaking 
Board; Notice of Filing of a Proposed Rule Change To Amend Rule G-14 
RTRS Procedures under MSRB Rule G-14 Regarding the Timing of Reporting 
Transactions in Municipal Securities to the MSRB and To Make a Related 
Amendment to Rule G-12

June 16, 2025.
    Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 
(``Act'' or ``Exchange Act'') \1\ and Rule 19b-4 thereunder,\2\ notice 
is hereby given that on June 10, 2025, the Municipal Securities 
Rulemaking Board (``MSRB'' or ``Board'') filed with the Securities and 
Exchange Commission (``SEC'' or

[[Page 26391]]

``Commission'') the proposed rule change as described in Items I, II, 
and III below, which Items have been prepared by the MSRB. The 
Commission is publishing this notice to solicit comments on the 
proposed rule change from interested persons.
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    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance 
of the Proposed Rule Change

    The MSRB filed with the Commission a proposed rule change to (i) 
amend Rule G-14 RTRS Procedures under MSRB Rule G-14, on reports of 
sales or purchases, to rescind a previously approved but not yet 
effective shortening of the amount of time within which brokers, 
dealers and municipal securities dealers (``dealers'') must report most 
transactions to the MSRB, reverting such timeframe to the currently 
effective 15-minute reporting timeframe, (ii) amend the
    Rule G-14 RTRS Procedures to eliminate two previously approved but 
not yet effective reporting exceptions and a manual trade indicator 
relating to the rescinded shortened timeframes, and (iii) make a 
related conforming amendment to MSRB Rule G-12, on uniform practice 
(``Rule G-12''), as described herein (the ``proposed rule change'').
    The provisions that would be rescinded by the proposed rule change 
were previously approved by the Commission on September 20, 2024 as 
part of a broader set of amendments which have not yet become effective 
(the ``2024 Amendments'').\3\ A portion of the 2024 Amendments would 
not be modified by this proposed rule change, as described below. If 
the Commission approves the proposed rule change, the MSRB will 
announce the effective date of the proposed rule change in a regulatory 
notice to be published on the MSRB website. The effective date(s) of 
the portions of the 2024 Amendments not modified by this proposed rule 
change will also be announced in such regulatory notice.
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    \3\ See Exchange Act Release No. 101118 (Sept. 20, 2024), 89 FR 
78955 (Sept. 26, 2024), File No. SR-MSRB-2024-01 (the ``2024 
Approval Order''). The MSRB has not announced the effective date of 
the 2024 Amendments. The text of the approved but not yet effective 
2024 Amendments is set forth in Exhibit 5 of Amendment No. 1 of File 
No. SR-MSRB-2024-01, available at https://www.msrb.org/sites/default/files/2024-07/MSRB-2024-01-A-1.pdf. See also MSRB Notice 
2024-12 (SEC Approves Amendments to MSRB Rule G-14 to Shorten 
Timeframe for Reporting Transactions in Municipal Securities) (Sept. 
20, 2024) (the ``2024 MSRB Notice''). Unless otherwise specifically 
noted, references to rule text are to the text as amended by the 
2024 Amendments.
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    The text of the proposed rule change is available on the MSRB's 
website at https://msrb.org/2025-SEC-Filings, at the MSRB's principal 
office, and at the Commission's Public Reference Room.

II. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

    In its filing with the Commission, the MSRB included statements 
concerning the purpose of and basis for the proposed rule change and 
discussed any comments it received on the proposed rule change. The 
text of these statements may be examined at the places specified in 
Item IV below. The MSRB has prepared summaries, set forth in Sections 
A, B, and C below, of the most significant aspects of such statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

1. Purpose
Background
    Dealers currently are required to report their transactions to the 
MSRB's Real-Time Transaction Reporting System (``RTRS'') within 15 
minutes of the Time of Trade,\4\ absent an exception,\5\ in accordance 
with Rule G-14, the Rule G-14 RTRS Procedures, and the RTRS Users 
Manual.\6\ On September 20, 2024, the Commission approved the 2024 
Amendments, which modified, among other things, the baseline 15-minute 
reporting requirement for reporting trades to RTRS in two ways: (i) 
reducing the deadline for reporting such trades to no later than one 
minute after the Time of Trade (the ``one-minute reporting 
requirement'') and (ii) requiring that trades be reported as soon as 
practicable, regardless of the amended deadline (the ``as soon as 
practicable requirement''). The 2024 Amendments added two new 
exceptions to the new one-minute reporting requirement for trades with 
a manual component \7\ and for trades by dealers with limited trading 
activity.\8\ The 2024 Amendments also included a requirement that 
dealers append a new manual trade indicator to identify all manual 
trades.\9\ As noted above, these provisions, while adopted by the MSRB 
and approved by the Commission, have not gone into effect.
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    \4\ Rule G-14 RTRS Procedures paragraph (d)(iii) defines ``Time 
of Trade'' as the time at which a contract is formed for a sale or 
purchase of municipal securities at a set quantity and set price.
    \5\ Transactions in securities without CUSIP numbers, 
transactions in municipal fund securities, and certain inter-dealer 
securities movements not eligible for comparison through a clearing 
agency are currently exempt from the reporting requirements under 
Rule G-14(b)(v). Other transactions, while subject to the reporting 
requirements of Rule G-14, currently have certain exceptions from 
the baseline 15-minute timeframe as described in Rule G-14 RTRS 
Procedures paragraph (a)(ii).
    \6\ The RTRS Users Manual is available at https://www.msrb.org/RTRS-Users-Manual.
    \7\ The 2024 Amendments added a definition of a trade with a 
manual component in paragraph (d)(xii) of Rule G-14 RTRS Procedures, 
an exception from the one-minute reporting timeframe for trades with 
a manual component in paragraph (a)(ii)(C)(2) of Rule G-14 RTRS 
Procedures, and requirements with respect to the timing and related 
matters for such reporting in Supplementary Material .02 of Rule G-
14.
    \8\ The 2024 Amendments added a definition of a dealer with 
limited trading activity in paragraph (d)(xi) of Rule G-14 RTRS 
Procedures, an exception from the one-minute reporting timeframe for 
trades by a dealer with limited trading activity in paragraph 
(a)(ii)(C)(1) of Rule G-14 RTRS Procedures, and requirements with 
respect to the timing and related matters for such reporting in 
Supplementary Material .01 of Rule G-14.
    \9\ The 2024 Amendments added a requirement in paragraph 
(b)(iv)(B)(4) of Rule G-14 RTRS Procedures that dealers report any 
trade with a manual component with a new special condition 
indicator.
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    Following the approval of the 2024 Amendments, the MSRB continued 
to engage with market participants and received further feedback 
expressing various concerns regarding aspects of the one-minute 
reporting requirement. These concerns emerged as dealers began 
considering the specific steps they would need to undertake to come 
into compliance with the 2024 Amendments that related both to 
additional scenarios involving potential trades with a manual component 
beyond those discussed in the 2024 Amendments, and to issues that could 
arise in the case of certain fully automated trades. Some of these 
scenarios raised the prospect that a potentially broader array of 
circumstances than previously anticipated during the course of the 
rulemaking for the 2024 Amendments may exist where, at this time, the 
adjustment of dealer systems and workflows, including those dependent 
on third party vendors or market utilities, associated with achieving 
and complying with the shortened reporting timeframes under the 2024 
Amendments might not be feasible in the near-term.
    In reviewing trade reporting data through the end of 2024 that 
reflected market practices since the 2022 trade reporting data used in 
connection with the 2024 Amendments, the MSRB has observed that trades 
that were likely reported electronically were being reported more 
rapidly in 2024 as

[[Page 26392]]

compared to 2022.\10\ The MSRB previously noted that, to the extent 
dealers are not already reporting trades as soon as practicable, the 
inclusion of the requirement for reporting as soon as practicable would 
have the effect of increasing the proportion of trades being reported 
within shorter timeframes than they currently are, without regard to a 
one-minute, five-minute or 15-minute deadline, potentially translating 
into significant improvement in market-wide average reporting times and 
in turn reduce market-wide lags in pricing information being made more 
widely available and reduce information arbitrage.\11\ The MSRB 
believes, as noted by at least one commenter on the 2024 Amendments, 
that the inclusion of the as soon as practicable requirement may, by 
itself, result in improvements in the timing of trade reporting, with 
the greatest improvements likely to occur for those trades currently 
being reported nearer to the 15-minute deadline.\12\
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    \10\ See infra Self-Regulatory Organization's Statement on 
Burden on Competition--Benefits, Costs, and Effect on Competition--
Trade Reporting Analysis, Table 2 and accompanying text.
    \11\ See letter from Ernesto A. Lanza, Chief Regulatory and 
Policy Officer, MSRB, to Vanessa Countryman, Secretary, Commission, 
dated July 18, 2024, at 17-18, available at https://www.msrb.org/sites/default/files/2024-07/Response-to-Comments-SR-MSRB-2024-01.pdf.
    \12\ See, e.g., letter to Ronald W. Smith, MSRB, and Jennifer 
Piorko Mitchell, Financial Industry Regulatory Authority 
(``FINRA''), from Kenneth E. Bentsen, Jr., President and CEO, 
Securities Industry and Financial Markets Association (``SIFMA''), 
dated October 3, 2022, at 7 (``SIFMA believes that adding a 
requirement to Rule G-14 that reports be made as soon as 
practicable, and the SROs providing guidance to broker-dealers on 
how they might best make improvements to their reporting practices 
in a practicable manner, would materially improve the timing of such 
trade reports without having to impose a radical one-minute 
mandate.'').
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    The MSRB believes that the 2024 Amendments, as modified by the 
proposed rule change, would serve to continue to enhance market 
transparency without the potential compliance burdens and costs 
associated with the one-minute reporting requirement and the use of a 
special condition indicator for trades with a manual component. The 
MSRB intends to continue monitoring for further improvements in trade 
reporting timing and to publish its findings for market participants 
and the general public.
    As a result, the MSRB has determined that it is appropriate at this 
time to rescind the one-minute reporting requirement and related 
provisions of the 2024 Amendments and revert the rule language to 
maintain the currently-effective 15-minute RTRS reporting standard. The 
MSRB has also determined to retain the as soon as practicable 
requirement and related provisions, as well as certain other clarifying 
amendments, of the 2024 Amendments. The proposed rule change, and the 
retained provisions of the 2024 Amendments, are described below.
Proposed Rule Change
    The proposed rule change would rescind certain provisions adopted 
in the 2024 Amendments. Specifically, the proposed rule change would:
     Revert the one-minute deadline for reporting trades to the 
existing 15-minute timeframe, so that all types of trades required to 
be reported within 15 minutes under the rule language prior to the 2024 
Amendments would continue to be subject to the 15-minute reporting 
requirement under paragraph (a)(ii) of Rule G-14 RTRS Procedures; \13\
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    \13\ The proposed rule change would also partially revert the 
change made by the 2024 Amendments to Rule G-12(f)(i), relating to 
the timing for submission of trades to be compared, to reflect the 
reversion from one minute to 15 minutes under the proposed rule 
change.
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     Eliminate the two new intra-day exceptions for dealers 
with limited trading activity and trades with a manual component by 
deleting paragraph (a)(ii)(C) of Rule G-14 RTRS Procedures and 
Supplementary Material .01 and .02 of Rule G-14, as well as deleting 
the definitions of dealer with limited trading activity in paragraph 
(d)(xi) of Rule G-14 RTRS Procedures and trade with a manual component 
in paragraph (d)(xii) of Rule G-14 RTRS Procedures, as such exceptions 
and related provisions are no longer relevant due to the rescinding of 
the one-minute reporting requirement; and
     Eliminate the new special condition indicator requirement 
for trades with a manual component by deleting paragraph (b)(iv)(B)(4) 
of Rule G-14 RTRS Procedures, as under the reverted rule there is no 
necessity for distinguishing between trades with a manual component and 
other trades.\14\
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    \14\ Paragraphs (b)(iv)(B)(5)-(7) would be renumbered to reflect 
this deletion.
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    In addition to the changes described above, the 2024 Amendments 
included certain changes that would, as a matter of substance, be 
retained and not be affected by this proposed rule change except with 
respect to certain non-substantive changes described below. The 
addition by the 2024 Amendments to paragraph (a)(ii) of Rule G-14 RTRS 
Procedures of the requirement that transactions effected with a Time of 
Trade during the hours of the RTRS Business Day must be reported as 
soon as practicable would be retained without change.\15\ In addition, 
Supplementary Material .03 added by the 2024 Amendments would be 
retained and renumbered as Supplementary Material .01, with minor non-
substantive grammatical and clarifying changes.\16\ During the 
rulemaking process in connection with the 2024 Amendments, the MSRB 
received general industry support for inclusion of these 
provisions,\17\ which harmonize the Rule G-14 RTRS Procedures with 
FINRA Rule 6730(a) and Supplementary Material .03 thereof in connection 
with Trade Reporting and Compliance Engine (``TRACE'') requirements for 
reporting TRACE-eligible securities. Retention of the as soon as 
practicable requirement in particular constitutes a key component of 
the basis for reverting the one-minute reporting requirement pursuant 
to this proposed rule change, as the MSRB believes that the as soon as 
practicable requirement would strengthen the existing trend since 2022 
of faster trade reporting in a manner that minimizes the burden on 
dealers.\18\
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    \15\ See Exchange Act Release No. 99402 (Jan. 19, 2024), 89 FR 
5384, 5386 (Jan. 26, 2024), File No. SR-MSRB-2024-01 (the ``2024 
Filing Notice''), at Section II.A.1, discussion under heading New 
Requirement To Report Trades ``as Soon as Practicable,'' for a full 
discussion of these provisions. See also 2024 MSRB Notice, Section 
B. New Requirement to Report Trades as Soon as Practicable, at 3-4. 
While the proposed rule change would revert a portion of the changes 
made by the 2024 Amendments to Rule G-12(f)(i) to reflect the 
reversion of the one-minute reporting timeframe back to 15 minutes, 
as described in supra note 13, the portion of such changes to Rule 
G-12(f)(i) reflecting the addition of the ``as soon as practicable'' 
language would be retained so that such trades must be submitted for 
comparison as soon as practicable. Another minor language change 
made to Information Facility 1 by the 2024 Amendments would also be 
retained without change.
    \16\ The word ``reporting'' would be added to the phrase 
``trades with a manual reporting component'' to provide greater 
clarity in light of the deletion of the substantive provisions and 
definition relating to the exception for trades with a manual 
component.
    \17\ See 2024 Filing Notice, 89 FR at 5403, Section II.C, 
discussion under heading As Soon as Practicable Requirement. See 
also letters to Vanessa A. Countryman, Secretary, Commission, from: 
Michael Decker, Senior Vice President, Bond Dealers of America, 
dated August 21, 2024, at 3; Melissa P. Hoots, Chief Executive 
Officer and Chief Operating Officer, Falcon Square Capital, LLC, 
dated August 21, 2024, at 4; and Matt Dalton, Chief Executive 
Officer, Belle Haven Investments, LP, dated August 21, 2024, at 5.
    \18\ See infra Self-Regulatory Organization's Statement on 
Burden on Competition--Benefits, Costs, and Effect on Competition--
Benefits.
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    Another change included in the 2024 Amendments that would not be 
affected by this proposed rule change and would be retained consists of 
language added to paragraph (a)(iv) of Rule G-14 RTRS Procedures 
regarding designation of late

[[Page 26393]]

trades and patterns or practices of late reporting without exceptional 
circumstances or reasonable justification.\19\ In line with these 
provisions, the MSRB expects that the regulatory authorities that 
examine dealers and enforce compliance with the reporting timeframes 
established under Rule G-14 RTRS Procedures will focus their 
examination for and enforcement of the rule's timing requirements on 
the consistency of timely reporting and the existence of effective 
controls to limit late reporting to exceptional circumstances or where 
reasonable justification exists for a late trade report, rather than on 
individual late trade report outliers. Notwithstanding such 
expectation, where facts and circumstances indicate that an individual 
late report was intentional or otherwise egregious, or could reasonably 
be viewed as potentially giving rise to an associated fair practice, 
fair pricing, best execution or other material regulatory concern under 
MSRB or Commission rules with respect to that or a related transaction, 
the regulatory authorities could reasonably determine to take action 
with respect to such late trade in the examination or enforcement 
context.\20\
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    \19\ See 2024 Filing Notice, 89 FR at 5391, Section II.A.1, 
discussion under heading Pattern or Practice of Late Trade 
Reporting, for a full discussion of these provisions. See also 2024 
MSRB Notice, Section F. Pattern or Practice of Late Trade Reporting; 
Exceptional Circumstances or Reasonable Justification, at 18-20.
    \20\ Dealers that seek to document system outages that might 
factor into whether exceptional circumstances or reasonable 
justification may exist for a late trade report can use the MSRB's 
Dealer System Outage Report process in MSRB Gateway to document 
system outages or other technology-related problems that affect 
their ability to comply with MSRB rules. Such reports are provided 
to authorities charged with enforcing MSRB rules.
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    Additional clarifying amendments from the 2024 Amendments that 
reorganize certain existing materials into more logical groupings, such 
as previously established special condition indicators, and clarifying 
the reporting timeframe for trades on an invalid RTTM trade date, would 
also be retained.\21\
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    \21\ See 2024 Filing Notice, 89 FR at 5392, Section II.A.1, 
discussion under heading Technical Amendments, for a full discussion 
of these provisions.
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2. Statutory Basis
    Section 15B(b)(2) of the Exchange Act \22\ provides that the MSRB 
shall propose and adopt rules to effect the purposes of the Exchange 
Act with respect to, among other matters, transactions in municipal 
securities effected by dealers. Section 15B(b)(2)(C) of the Exchange 
Act \23\ further provides, among other things, that the MSRB's rules 
shall be designed to prevent fraudulent and manipulative acts and 
practices, to promote just and equitable principles of trade, to foster 
cooperation and coordination with persons engaged in regulating, 
clearing, settling, processing information with respect to, and 
facilitating transactions in municipal securities and municipal 
financial products, to remove impediments to and perfect the mechanism 
of a free and open market in municipal securities and municipal 
financial products, and, in general, to protect investors, municipal 
entities, obligated persons, and the public interest.
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    \22\ 15 U.S.C. 78o-4(b)(2).
    \23\ 15 U.S.C. 78o-4(b)(2)(C).
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    The MSRB believes the proposed rule change is consistent with 
Section 15B(b)(2)(C) of the Exchange Act \24\ because it would promote 
just and equitable principles of trade, foster cooperation and 
coordination with personnel engaged in regulating and facilitating 
transactions in municipal securities, remove impediments to a free and 
open market in municipal securities and generally protect investors and 
the public interest. As discussed above, the MSRB believes that the 
proposed rule change is appropriate at this time, given the additional 
information obtained since the approval of the 2024 Amendments. The 
additional information suggests that both the burdens of the shortened 
reporting timeframe (together with the associated exceptions and manual 
trade flag) in the 2024 Amendments may be higher than initially 
estimated and the net positive impact of the tightened timeframe, as 
compared to not changing the timeframe, may not be as large as 
originally estimated in light of observed improvements in actual 
reporting performance by dealers between 2022 and 2024 under the 
current 15-minute standard. The proposed rule change represents a 
responsive adjustment to the 2024 Amendments to address market 
participants' feasibility and compliance concerns that could have 
impeded the achievement of the expected benefits thereof.
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    \24\ Id.
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    The proposed rule change is intended to alleviate compliance 
challenges and avoid potential unintended consequences--particularly 
given the broad prevalence of manual and hybrid trading workflows for 
municipal securities. Therefore, the MSRB believes the proposed rule 
change would help achieve the purposes of the Exchange Act to remove 
impediments to and perfect the mechanism of a free and open market in 
municipal securities and to protect investors by enhancing and 
facilitating dealer compliance without imposing undue costs and burdens 
that are not necessary or appropriate at this time, thereby making it 
more likely that the goal of greater transparency for market 
participants would occur in a more cost-efficient manner. The MSRB 
believes that the proposed rule change would continue to promote the 
reduction in information asymmetry between market professionals and 
retail investors sought by the 2024 Amendments through the retention of 
the as soon as practicable requirement without creating the additional 
process burdens resulting from the classification and flagging of 
trades as having or not having a manual trade component or being 
effected by dealers with differing levels of trade activity, which had 
the potential to create different treatment by dealers for trades 
fitting one or another of such categories.
    The MSRB further believes that the proposed rule change would 
remove impediments to and enhance the operation of a free and open 
market in municipal securities by enabling dealers to better comply 
with applicable reporting timeframes by promoting further enhancements 
to participants' systems and processes for reporting trades in a manner 
best suited to their respective business models. Thus, under the as 
soon as practicable requirement, dealers would be able to make 
appropriate enhancements consistent with their own business practices 
without needing to adapt their systems and processes to the heightened 
complexities of, and without the imposition of the added costs 
associated with, a significantly shortened reporting timeframe and 
associated provisions that would be rescinded by the proposed rule 
change.
    The proposed rule change would promote just and equitable 
principles of trade because it would reduce information asymmetry 
between market professionals (such as dealers and institutional 
investors) and retail investors by ensuring increased access to more 
timely information about executed municipal securities transactions for 
all investors. Currently, market professionals may in some 
circumstances have better or more rapid access to information about 
trade prices through market venues to which retail investors do not 
have access, and the reduction in the timeframe for trade reporting 
would shorten or eliminate the period during which any such asymmetry 
in access to such information may exist.

[[Page 26394]]

    The proposed rule change would foster cooperation and coordination 
with persons engaged in regulating and processing information, 
facilitating a consistent standard for trade reporting across many 
fixed income products, including municipal securities. The 2024 
Amendments were developed in close coordination with FINRA, which 
adopted a similar shortened trade reporting requirement for many TRACE-
eligible securities, and the MSRB and FINRA continue to work in 
coordination on issues that have presented since such adoption.\25\ 
Fostering a consistent approach across classes of securities would 
facilitate greater and more efficient compliance among MSRB-registered 
dealers, the majority of which also transact in other fixed income 
securities that are subject to FINRA's regulatory authority. Consistent 
trade reporting requirements tend to reduce the risk of potential 
confusion and may reduce compliance burdens resulting from inconsistent 
obligations and standards for different classes of securities. The 
proposed rule change would continue to promote regulatory consistency, 
reducing potential errors caused by market participants' imperfect 
application of differing standards when executing and reporting 
transactions in municipal securities.
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    \25\ See FINRA, Updating TRACE Reporting Timeframes (Feb. 5, 
2025), available at https://www.finra.org/media-center/blog/updating-trace-reporting-timeframes; MSRB, MSRB Board Authorizes 
Further Amendments to Rule G-14, Withdraws Pre-Trade Concept Release 
(Mar. 7, 2025), available at https://www.msrb.org/Press-Releases/MSRB-Board-Authorizes-Further-Amendments-Rule-G-14-Withdraws-Pre-Trade-Concept.
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    Therefore, the MSRB believes that the proposed rule change 
satisfies the applicable requirements of Section 15B(b)(2)(C) of the 
Exchange Act.\26\
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    \26\ 15 U.S.C. 78o-4(b)(2)(C).
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B. Self-Regulatory Organization's Statement on Burden on Competition

    Section 15B(b)(2)(C) of the Exchange Act requires that MSRB rules 
not be designed to impose any burden on competition not necessary or 
appropriate in furtherance of the purposes of the Exchange Act.\27\ The 
proposed rule change would (i) eliminate the reduction in timeframe 
within which dealers must report trades to RTRS previously adopted by 
the MSRB but not yet made effective, (ii) eliminate two previously 
approved but not yet effective reporting exceptions and a manual trade 
indicator, and (iii) make a conforming amendment to Rule G-12. The MSRB 
believes the proposed rule change would not impose any burden on 
competition, as the proposed rule change would likely further 
accelerate the trade reporting process without adding significant costs 
to dealers and would be applicable to all dealers equally. Therefore, 
the MSRB does not believe the proposed rule change would result in any 
burden on competition that is not necessary or appropriate in 
furtherance of the purposes of the Exchange Act.
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    \27\ Id.
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    In making this determination, MSRB staff was guided by the MSRB's 
Policy on the Use of Economic Analysis in MSRB Rulemaking.\28\ In 
accordance with this policy, the MSRB evaluated the potential impacts 
on competition of not only the provisions of the proposed rule change 
but also of the retained provisions of the 2024 Amendments intended to 
encourage dealers to further accelerate the trade reporting process. 
The one-minute reporting requirement, which would be amended by the 
proposed rule change, and the as soon as practicable requirement, which 
would be retained, were distinct but overlapping provisions of the 2024 
Amendments both of which were designed to achieve more timely reporting 
of trades. While the one-minute reporting requirement represented a 
prescriptive approach to this goal, the as soon as practicable 
requirement represented a principles-based approach that would serve to 
enhance post-trade market transparency, particularly for individual 
(retail) investors, without the additional compliance burdens 
associated with a significantly shortened reporting timeframe for 
dealers. Historically, when compared to other securities markets, the 
municipal securities market has been considered to trade less 
frequently, with only about one percent of all municipal securities 
trading on a given trading day. In addition, pre-trade quotes are not 
widely available to all investors, especially retail investors who may 
not purchase vendor pricing tools and may be more reliant on post trade 
data.\29\ Therefore, post trade data is important information available 
to these investors, and the reporting of more contemporaneous 
transactions sooner would benefit investors for the relevant security 
as well as other comparable securities. In addition, analogous trade 
reporting rules for other fixed income securities markets already 
contain the as soon as practicable requirement; \30\ consequently, the 
proposed rule change is also intended to make trade reporting 
requirements for municipal securities consistent with analogous 
reporting requirements for other fixed income securities.\31\
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    \28\ The Policy on the Use of Economic Analysis in MSRB 
Rulemaking is available at https://www.msrb.org/Policy-Use-Economic-Analysis-MSRB-Rulemaking. In evaluating whether there was a burden 
on competition, the MSRB was guided by its principles that require 
the MSRB to consider costs and benefits of a rule change, its impact 
on capital formation and the main reasonable alternative regulatory 
approaches.
    \29\ See Wu, Simon Z., John Bagley and Marcelo Vieira, 
``Analysis of Municipal Securities Pre-Trade Data from Alternative 
Trading Systems,'' Research Paper, Municipal Securities Rulemaking 
Board, October 2018; Government Accountability Office (``GAO''), 
``Municipal Securities: Overview of Market Structure, Pricing, and 
Regulation,'' Report to Congressional Committees, January 2012, at 
p. 6; Green, Richard C., Burton Hollifield, and Norman 
Sch[uuml]rhoff. ``Financial intermediation and the costs of trading 
in an opaque market.'' The Review of Financial Studies 20.2 (2007), 
at pp. 275-314.
    \30\ FINRA Rule 6730(a) states that ``[a] member must report a 
transaction in a TRACE-Eligible Security as soon as practicable, but 
no later than within 15 minutes of the Time of Execution, except as 
otherwise specifically provided below.''
    \31\ See supra note 25 and accompanying text.
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Relevant Baselines
    The MSRB's Policy on the Use of Economic Analysis outlines that 
rulemaking will articulate a baseline against which to measure the 
likely economic impact of the proposed rule change,\32\ which is 
essential in considering the likely costs and benefits of a proposed 
rule change when the proposal is fully implemented (future state).
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    \32\ See supra note 28. The policy identifies the baseline as 
``an assessment of the status of the markets and participants 
potentially affected directly or indirectly by a proposed rule 
change (collectively, the ``affected parties'') in the absence of 
the proposed rule change being implemented.''

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[[Page 26395]]

    For this proposed rule change, the baseline is Rule G-14 RTRS 
Procedures (a)(ii) currently in effect that require transactions to be 
reported within 15 minutes after the Time of Trade with limited 
exceptions, but does not require that trades be reported as soon as 
practicable. This is because the 2024 Amendments, while approved by the 
SEC, have not yet gone into effect and therefore have never been 
implemented. In fact, the MSRB has never established an effective date 
for the 2024 Amendments, so presumably dealers are still abiding by the 
current practice, with no effective date expected to become effective 
in the foreseeable future.\33\ Therefore, the future state for this 
analysis would consist of the proposed rule change maintaining the 
currently-effective 15-minute reporting requirement while retaining and 
implementing the as soon as practicable requirement of the 2024 
Amendments, as a comparison to the current baseline state without the 
as soon as practicable requirement.
---------------------------------------------------------------------------

    \33\ The MSRB had previously suggested that it would provide an 
extended effective date for the one-minute reporting requirement, 
with further extended periods for effectiveness for trades with a 
manual component, due to the complexity of the one-minute reporting 
requirement and the related exceptions and trade flagging 
requirements. See 2024 Filing Notice, 89 FR at 5392, at Section 
II.A.1, discussion under heading Effective Date and Implementation.
---------------------------------------------------------------------------

    Separately, the MSRB is also assessing the impact of implementing 
all of the requirements of the 2024 Amendments as a comparison to the 
current proposed rule change as one of the regulatory alternatives 
(Alternative 1) in the section below. The 2024 Amendments, if they were 
to become effective, would shorten the reporting timeframe for most 
transactions from 15 minutes to one minute after the time of trade, 
would require dealers to report certain transactions with a new trade 
indicator, would introduce two new intra-day exceptions to the one-
minute reporting requirement and would require that trades be reported 
as soon as practicable.
Benefits, Costs, and Effect on Competition
Trade Reporting Analysis
    The MSRB's updated analysis shows that most trades are indeed 
reported much sooner than the currently operative 15-minute trade 
reporting deadline in 2024,\34\ potentially due at least in part to the 
advancement in technology. Specifically, as illustrated in Table 1 
below, in 2024, out of all reportable municipal securities trades 
required to be reported within 15 minutes that are not subject to 
another end of day reporting exception or a post-trade day reporting 
exception,\35\ approximately 80.8 percent of trades were already 
reported within one minute after the Time of Trade.\36\ In addition, 
approximately 17.3 percent of trades were reported between one minute 
and five minutes after the Time of Trade, for a combined total of 98.1 
percent that were reported within five minutes. Therefore, most trades 
already satisfy a shorter than 15-minute reporting requirement. In 
addition, the MSRB observed a noticeable difference in the speed of 
trade reporting by different trade size groups, with the reporting time 
increasing with trade size. While 82.6 percent of trades with trade 
size of $100,000 par value or less (approximately 83.7 percent of all 
trades) were reported within one minute in 2024, only 42.8 percent of 
trades with trade size between $1,000,000 and $5,000,000 par value and 
28.8 percent of trades with trade size above $5,000,000 par value were 
reported within one minute. A possible explanation is that larger 
institutional-sized trades are more likely to be executed via non-
electronic means and may rely upon more manual processing steps.\37\ On 
the other hand, smaller-sized trades are more likely to be executed and 
processed electronically, which could facilitate faster trade 
reporting.
---------------------------------------------------------------------------

    \34\ In 2024, while the speed of trade reporting increased, RTRS 
also had the highest number of trades on record since its 
implementation in 2005, although the amount of par value traded was 
not a record high.
    \35\ See Rule G-14 RTRS Procedures paragraphs (a)(ii)(A) and (B) 
(as such provisions were redesignated by the 2024 Amendments) for 
end of trade day reporting exceptions and post-trade day reporting 
exceptions.
    \36\ The analysis in this rule filing only includes trades 
reportable within 15 minutes by dealers and excludes trades that are 
exempt from the current 15-minute reporting time including, for 
example, trades flagged as being executed at the List Offering or 
Takedown Transactions, trades in short-term instruments maturing in 
nine months or less, Auction Rate Securities, Variable Rate Demand 
Obligations, trades in commercial paper, as well as trades ``away 
from market,'' among other exceptions. See Rule G-14 RTRS Procedures 
paragraphs (a)(ii)(A) and (B) (as such provisions were redesignated 
by the 2024 Amendments). For purposes of the analysis in this 
section, if an initially reported trade was corrected later, the 
later timestamp was used for calculating the trade reporting time 
more conservatively. All figures are approximate.
    \37\ MSRB staff conducted oral interviews with dealers and data 
providers in the fall of 2022 and the winter and spring of 2023 and 
was informed that larger institutional-sized trades are more likely 
to be executed via negotiations and involve manual processes.

                                            Table 1--Trade Report Time by Trade Size--Cumulative Percentages
                                                             [January 2024 to December 2024]
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                All eligible     $100,000 or       >$100,000-          >=$1,000,000-        >$5,000,000
        Difference between execution and reported time           trades (%)       less (%)        $999,999 (%)        $5,000,000 (%)            (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
15 Seconds...................................................            34.2            35.7              28.5                 13.1                 7.8
30 Seconds...................................................            56.7            58.6              49.7                 24.9                15.3
1 Minute.....................................................            80.8            82.6              74.4                 42.8                28.8
2 Minutes....................................................            93.4            94.7              89.1                 67.4                54.0
3 Minutes....................................................            96.5            97.3              93.9                 79.8                70.1
5 Minutes....................................................            98.1            98.5              96.7                 89.4                84.4
10 Minutes...................................................            99.2            99.4              98.6                 96.1                94.1
15 Minutes...................................................            99.5            99.6              99.1                 97.7                96.1
30 Minutes...................................................            99.7            99.8              99.4                 98.8                97.7
1 Hour.......................................................            99.9            99.9              99.8                 99.6                99.4
>1 Hour......................................................           100.0           100.0             100.0                100.0               100.0
                                                               ..............  ..............  .................  ......................  ..............
Share of Eligible Trades.....................................           100.0            83.7              14.7                  1.4                 0.3
--------------------------------------------------------------------------------------------------------------------------------------------------------


[[Page 26396]]

    In addition, the MSRB observed noticeable decreases in the time it 
took to report trades in 2024 compared to 2022, where approximately 
78.1 percent were reported within one minute in 2022 and a combined 
total of 97.9 percent were reported within five minutes, compared to 
80.8 percent reported within one minute in 2024 and 98.1 percent within 
five minutes (Table 2). The MSRB is also encouraged to observe that the 
improvements in timely trade reporting were even more significant for 
trades reporting within 15 seconds and 30 seconds, from 24.8% in 2022 
to 34.2% in 2024 for 15 seconds, and from 52.7% in 2022 to 56.7% in 
2024 for 30 seconds (see Table 2).

          Table 2--Trade Report Time Comparison: 2022 and 2024
------------------------------------------------------------------------
    Difference between execution and
              reported time                2022 data (%)   2024 data (%)
------------------------------------------------------------------------
15 Seconds..............................            24.8            34.2
30 Seconds..............................            52.7            56.7
1 Minute................................            78.1            80.8
5 Minutes...............................            97.9            98.1
10 Minutes..............................            99.3            99.2
15 Minutes..............................            99.6            99.5
------------------------------------------------------------------------

Benefits
    The primary benefit of retaining and implementing the as soon as 
practicable requirement is that it would encourage dealers to continue 
to reduce trade reporting times due to the provision's obligation and 
thereby increase overall price transparency. Between 2022 and 2024, the 
municipal securities market not only experienced greater trading 
activity but also faster trade reporting, especially for the number of 
trades reported within one minute. The MSRB believes the proposed rule 
change may further accelerate trade reporting, particularly for some 
trades that are currently being reported closer to the 15-minute 
deadline. Hence, by retaining and implementing the as soon as 
practicable requirement, the MSRB believes investors could benefit from 
enhanced price transparency because of potentially faster trade 
reporting.
    With limited trading volume on a particular day, municipal 
securities information on trades in the same security as well as in 
other comparable municipal securities would both be valuable in pricing 
a security.\38\ Furthermore, with far fewer trades in municipal 
securities when compared to treasury and corporate bonds, the MSRB also 
expects that each additional timely data point from post trade 
reporting in municipal securities would potentially be more valuable to 
investors and other market participants than a data point from these 
other markets. In addition to investors, issuers, underwriters and 
other market participants such as data vendors would also experience 
some additional benefit from faster data transmission. Finally, 
retaining and aligning the as soon as practicable requirement for 
municipal securities with other fixed income securities would reduce 
any confusion for dealers who trade all these fixed-income securities, 
bringing regulatory consistency across fixed-income markets.\39\
---------------------------------------------------------------------------

    \38\ See GAO, ``Municipal Securities: Overview of Market 
Structure, Pricing, and Regulation,'' Report to Congressional 
Committees, January 2012, at p. 12 (``Broker-dealers we spoke with 
said that the price of a recently reported interdealer trade for a 
security was a particularly good indication of its value for that 
segment of the market. However, if a security has not traded 
recently, they said they instead look for recent trades in 
comparable securities.'').
    \39\ A few of the commenters who responded to the original 
request for comment mentioned that many dealers are already adhering 
to the ``as soon as practicable'' language as it is already part of 
FINRA rules on trade reporting. See supra note 17.
---------------------------------------------------------------------------

    Given the improvement in trade reporting time between 2022 and 
2024, the MSRB is planning to continue analyzing trade data and 
monitoring for reporting patterns that emerge with respect to timing of 
reporting.
Costs
    The MSRB acknowledges that dealers would likely incur minor 
additional costs, relative to the current state, to implement changes 
from the proposed rule change along with the retained portions of the 
2024 Amendments. These additional costs would likely include one time 
or upfront costs (e.g., setting up and/or revising policies and 
procedures, education and training), and ongoing compliance costs to 
ensure changes from the proposed rule change are followed. Firms that 
also trade other fixed-income securities in addition to municipal 
securities, and therefore are already subject to the as soon as 
practicable standard for other fixed income products, may experience 
lower costs to implement this aspect of the retained 2024 Amendments 
than the MSRB's estimates because those firms can adapt their existing 
compliance program for municipal securities.
Upfront Costs
    The MSRB expects that dealers would expend resources to implement a 
thoughtful supervisory and compliance regime in order to satisfy the as 
soon as practicable requirement of the retained portions of the 2024 
Amendments. It is possible that dealers may need to seek appropriate 
advice from in-house and/or outside legal and compliance professionals 
to revise policies and procedures in compliance with the proposed rule 
change. The MSRB anticipates firms would devote approximately 11 hours 
to developing new policies and procedures to address the as soon as 
practicable requirement. This process is estimated to cost each dealer 
$5,068.\40\ Additionally, before the proposed rule change and the 
retained portions of the 2024 Amendments become effective, the MSRB 
expects that a compliance professional would devote time to training 
and educating registered representatives and others to ensure 
compliance with the as soon as practicable requirement. The total cost 
of training and education is estimated to be $1,179. The MSRB therefore 
estimates the total upfront costs to be $6,246 (see Table 3).
---------------------------------------------------------------------------

    \40\ The hourly rate data was gathered from the Commission's 
Amendments to Exchange Act Rule 3b-16. See Exchange Act Release No. 
94062 (Sep. 20, 2022), 17 CFR parts 232, 240, 242, 249 (Jan. 26, 
2022) (File No. S7-02-22), p. 477 n. 1102 (citing the original 
source of the data from SIFMA Management & Professional Earnings in 
the Securities Industry 2013). The data reflects the 2024 hourly 
rate level after adjusting for the annual wage inflation between 
2013 and 2024, using the Federal Reserve Bank of St. Louis 
Employment Cost Index: Wages and Salaries Private Industry, 
available at: https://fred.stlouisfed.org/series/ECIWAG. The MSRB 
uses a blended hourly rate of $286 for a Registered Representative, 
$379 for a Compliance Manager, $448 for an In-House Compliance 
Attorney, $497 for Outside Legal Counsel, $589 for a Director of 
Compliance and $670 for the Chief Compliance Officer, and estimates 
a total of 17 hours for dealers to update policies.

[[Page 26397]]



                              Table 3--Estimated Upfront Costs for Each Dealer \41\
----------------------------------------------------------------------------------------------------------------
                                                                                     Number of
                         Cost components                            Hourly rate        hours       Cost per firm
----------------------------------------------------------------------------------------------------------------
Upfront Costs:                                                    ..............  ..............  ..............
(a) Revision of Policies and Procedures:                          ..............  ..............  ..............
    Registered Representative...................................            $286               2            $571
    Compliance Manager..........................................             379               2             759
    In-House Compliance Counsel.................................             448               2             895
    Outside Legal Counsel.......................................             497               2             994
    Director of Compliance......................................             589               2           1,179
    Chief Compliance Officer (CCO)..............................             670               1             670
        Subtotal................................................  ..............  ..............           5,068
(b) Training and Education                                        ..............  ..............  ..............
    Director of Compliance......................................             589               2           1,179
        Subtotal................................................  ..............  ..............           1,179
                                                                 -----------------------------------------------
            Total Upfront Costs.................................  ..............  ..............           6,246
----------------------------------------------------------------------------------------------------------------

Ongoing Compliance Costs
    The MSRB anticipates relatively minor annual ongoing costs of 
promoting compliance with the as soon as practicable requirement. To do 
so, firms would develop compliance training and supervisory procedures 
to review trades on a periodic basis. The total cost of compliance 
personnel to monitor, review and educate trading desks is estimated to 
be $1,179 per year (see Table 4). Comparatively speaking, these ongoing 
compliance costs may not significantly exceed the costs in the current 
baseline, as the MSRB believes that all dealers should already have 
compliance programs in place ensuring fidelity to the current trade 
reporting requirement, and the vast majority of dealers that trade 
other fixed-income securities in addition to municipal securities can 
adapt their existing compliance programs for municipal securities.
---------------------------------------------------------------------------

    \41\ Numbers in the table have been rounded to the dollar; 
therefore, totals may not exactly match.

               Table 4--Estimated Ongoing Annual Training and Education Costs for Each Dealer \42\
----------------------------------------------------------------------------------------------------------------
                                                                                     Number of
                         Cost components                            Hourly rate        hours       Cost per firm
----------------------------------------------------------------------------------------------------------------
Ongoing Annual Costs                                              ..............  ..............  ..............
(a) Training, Education and Supervisory                           ..............  ..............  ..............
Procedures
    Director of Compliance......................................            $589               2          $1,179
                                                                 -----------------------------------------------
                                                                  ..............  ..............           1,179
----------------------------------------------------------------------------------------------------------------

Effect on Competition, Efficiency and Capital Formation
---------------------------------------------------------------------------

    \42\ The MSRB estimates a total of two hours per year for 
Director of Compliance ($589 per hour) to conduct training, 
education and to engage in supervisory activities under their 
policies and procedures for each dealer.
---------------------------------------------------------------------------

    The MSRB believes the proposed rule change would improve market 
efficiency by encouraging the industry's continued movement towards 
speedy trade reporting. Investors would likely benefit from a further 
reduction in trade reporting time, which would generate additional 
benefits for investors from more immediate post-trade transparency and 
potentially lower transaction costs. Thus, it is possible that the 
proposed rule change would lead to greater investor participation and 
further stimulate market activity by encouraging more trading by 
existing investors and/or bring in new investors to the municipal 
securities market over the long term and contribute to an overall 
increase in capital formation. Finally, the harmonization of reporting 
requirements for municipal securities with other fixed-income markets 
would create consistency for dealers who have trading operations in all 
these markets and would thus increase efficiency in terms of their 
compliance burdens. Therefore, the MSRB believes that the proposed rule 
change would facilitate capital formation.
    Dealers may be impacted by the proposed rule change through any 
upfront costs of revising policies and procedures and ongoing 
compliance costs; however, the broader impact on competition in the 
municipal securities market is expected to be minor, as the requirement 
applies to all dealers equally. The MSRB acknowledges that smaller 
dealers may bear proportionately higher upfront costs than larger 
dealers, but the relatively modest upfront costs borne by dealers 
overall are necessary to ensure a uniform standard across all dealers 
and to bring the municipal securities market in alignment with other 
securities markets. Therefore, the MSRB does not believe the ``as soon 
as practicable'' requirement would result in any burden on competition 
that is not necessary or appropriate in furtherance of the purposes of 
the Exchange Act.
Identifying and Evaluating Reasonable Alternative Regulatory Approaches
Alternative 1
    The MSRB has considered and evaluated reasonable regulatory 
alternatives. One alternative the MSRB analyzed was to fully retain the 
2024 Amendments as approved. This alternative would require all trades 
reported within one minute after the Time of Trade for active dealers 
that report annually, 2,500 trades or more in one of the past two 
years, except for manual trades which would be required to follow a 
three-year phased-in schedule from 15 minutes to five

[[Page 26398]]

minutes trade reporting. In addition, this alternative would require 
all dealers to report certain transactions with a new trade indicator. 
Finally, this alternative would also require that trades be reported as 
soon as practicable. While this alternative would likely further 
accelerate the trade reporting process when compared to the current 
state, it would also impose substantial technology subscription or 
upgrade expenses for active dealers who are currently not close to 
reporting all fully automated trades within one minute,\43\ and 
additional compliance and system costs for all dealers to provide a new 
trade indicator.
---------------------------------------------------------------------------

    \43\ See 2024 Approval Order, 89 FR at 78961-62 (discussing the 
MSRB's consideration of potential technological costs).
---------------------------------------------------------------------------

    Per MSRB's prior estimate, it would be at least $6.8 million total 
for the annual ongoing technology subscription costs for the industry 
based on the 2022 data, in addition to the estimated $5.2 million for 
the upfront costs to revise policy and procedures and to conduct 
training and education.\44\ Furthermore, there would be additional 
costs for system development to flag manual trades, and to ensure that 
manual trades' reporting time to be within five minutes after the Time 
of Trade eventually. While the MSRB did not have sufficient data to 
provide an estimate on the costs of reporting the trade indicator by 
dealers, based on further information received from dealers since 
approval of the 2024 Amendments,\45\ defining the manual trades may not 
be straightforward, which would further amplify the time and costs to 
implement the approved amendments to Rule G-14.\46\
---------------------------------------------------------------------------

    \44\ See Amendment No. 1 to File No. SR-MSRB-2024-01, Revised 
Table 4, p. 15, available at https://www.msrb.org/sites/default/files/2024-07/MSRB-2024-01-A-1.pdf.
    \45\ See supra Self-Regulatory Organization's Statement of the 
Purpose of, and Statutory Basis for, the Proposed Rule Change--
Purpose--Background.
    \46\ See 2024 Approval Order, 89 FR at 78960-62 (summarizing 
stakeholder concerns and MSRB considerations of potential costs).
---------------------------------------------------------------------------

    Therefore, the MSRB believes the proposed rule change is, on 
balance, superior to the 2024 Amendments because of the significantly 
reduced cost estimate on implementation. While eliminating the one-
minute reporting requirement would likely yield lower transparency 
benefits, based on the trend observed with 2024 data, the MSRB is 
cautiously optimistic that the industry would continue the trend of 
gradually moving towards faster trade reporting by its own volition, 
further propelled by the addition of the as soon as practicable 
requirement that would be retained from the 2024 Amendments, and 
greater electronification. As previously mentioned, the MSRB is 
encouraged to see an improvement in the trade reporting times between 
2022 and 2024. The number of trades reported within 15 seconds 
increased from 24.8% to 34.2% while trades reported within 30 seconds 
increased from 52.7% to 56.7% between 2022 and 2024. One possible 
explanation for this improvement is the continued electronification of 
municipal securities trading, and the MSRB would like to monitor future 
progress with the proposed rule change.
Alternative 2
    Another alternative the MSRB considered was to rescind the 2024 
Amendments entirely, including the as soon as practicable requirement. 
Essentially, this alternative would revert Rule G-14 to the currently 
operative version which was last amended in 2015. While this 
alternative certainly would not impose any additional costs to dealers, 
trade reporting requirements for municipal securities would continue to 
not align with analogous trade reporting requirements for other fixed 
income securities that already contain the as soon as practicable 
requirement. The MSRB believes that such an alignment would provide 
greater regulatory consistency in the trade reporting and compliance 
process, and reduce confusion for dealers that trade both municipal 
securities and other fixed income securities. In addition, the proposed 
rule change would likely result in a further shortening of trade 
reporting time and hence increase market transparency, without imposing 
a significant cost on the industry.

C. Self-Regulatory Organization's Statement on Comments on the Proposed 
Rule Change Received From Members, Participants, or Others

    Written comments were neither solicited nor received on the 
proposed rule change.

III. Date of Effectiveness of the Proposed Rule Change and Timing for 
Commission Action

    Within 45 days of the date of publication of this notice in the 
Federal Register or within such longer period of up to 90 days (i) as 
the Commission may designate if it finds such longer period to be 
appropriate and publishes its reasons for so finding or (ii) as to 
which the self-regulatory organization consents, the Commission will:
    (A) by order approve or disapprove such proposed rule change, or
    (B) institute proceedings to determine whether the proposed rule 
change should be disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views, and 
arguments concerning the foregoing, including whether the proposed rule 
change is consistent with the Act. Comments may be submitted by any of 
the following methods:

Electronic Comments

     Use the Commission's internet comment form (https://www.sec.gov/rules/sro.shtml); or
     Send an email to [email protected]. Please 
include File Number SR-MSRB-2025-01 on the subject line.

Paper Comments

     Send paper comments in triplicate to Secretary, Securities 
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.

    All submissions should refer to File Number SR-MSRB-2025-01. This 
file number should be included on the subject line if email is used. To 
help the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's internet website (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all 
written statements with respect to the proposed rule change that are 
filed with the Commission, and all written communications relating to 
the proposed rule change between the Commission and any person, other 
than those that may be withheld from the public in accordance with the 
provisions of 5 U.S.C. 552, will be available for website viewing and 
printing in the Commission's Public Reference Room, 100 F Street NE, 
Washington, DC 20549 on official business days between the hours of 
10:00 a.m. and 3:00 p.m. Copies of the filing also will be available 
for inspection and copying at the principal office of the MSRB. Do not 
include personal identifiable information in submissions; you should 
submit only information that you wish to make available publicly. We 
may redact in part or withhold entirely from publication submitted 
material that is obscene or subject to copyright protection. All 
submissions should refer to File Number SR-MSRB-2025-01 and should be 
submitted on or before July 11, 2025.


[[Page 26399]]


    For the Commission, pursuant to delegated authority.\47\
---------------------------------------------------------------------------

    \47\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------

Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2025-11292 Filed 6-18-25; 8:45 am]
BILLING CODE 8011-01-P