Category: Current Regulatory Topics

The MSRB is asking for comments on Draft Amendments to MSRB Rules on Primary Offering Prices. The Notice, 2018-15, asks for responses by 9.17.18.

There are three topics covered in the request; free-to-trade wires, additional information for the issuer, and the timeframe of payments of group net sales credits (to align them with the payment of net designated credits).

What’s Prevailing with Prevailing Market Price (PMP)

In 2014, when Malcolm Northam, then the head of Market Regulation for FINRA, spoke in front of the St. Louis Municipal Bond Club Outing and asked the question “Has everyone here read the SEC’s “Report on the Municipal Securities Market?”(July 31, 2012), very few hands were raised. But there’s no doubt that there’s been a lot more attention paid to the report since “Mac” challenged the room; many of the recommendations made by the SEC in their report have since been answered by the MSRB in the form of both new rules, and changes to existing rules. Outing members would have had to read no further than the Executive Summary (the first ten pages) to understand the changes that were to come.

This article is my take on various sections of rule changes that Dealers should keep in mind when developing their WSPs as regards to “mark-up”. While the rule has already gone into effect (May 14 2018), there are still many details that Dealers are working on in order to make sure that they have correctly interpreted the Rule.

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