MSRB Regulatory Notice 2018-24 MSRB Answers FAQs Regarding Use of Municipal Advisory Client Lists and Case Studies under MSRB Rule G-40
On June 27, 2018, the MSRB sought public comment on a draft set of frequently asked questions (FAQs) related to the application of MSRB Rule G-40, on advertising by municipal advisors, to the use of municipal advisory client lists and case studies by municipal advisors. The MSRB received three comment letters and revised the draft FAQs to reflect those comments as well as additional insight gained from the MSRB’s ongoing engagement with the industry concerning compliance with Rule G-40.
MSRB Regulatory Notice 2018-25 Request for Comment on Application of Content Standards to Advertisements by Municipal Advisors under MSRB Rule G-40
The MSRB requests comment from market participants and the public on a draft compliance resource regarding the application of the content standards under MSRB Rule G-40, on advertising by municipal advisors. This request seeks information and insight from commenters to further inform the MSRB’s development of the compliance resource for planned publication. The MSRB invites market participants and the public to submit comments in response to this request, along with any other information that they believe would be useful to the MSRB in developing this compliance resource. Information may be submitted through October 17, 2018 in electronic or paper form.
This Notice provides firms with information regarding recent guidance issued by staff of the SEC’s Division of Trading and Markets regarding the use of recordkeeping services provided by third parties to preserve records pursuant to SEA Section 17(a) and SEA Rule 17a-4.
FINRA Regulatory Notice 18-29 FINRA Reminds Firms of Their Obligations When Effecting OTC Trades in Equity Securities on a Net Basis
FINRA is issuing this Notice to remind firms of their obligations under the FINRA trade reporting rules and other applicable FINRA and Securities and Exchange Commission (SEC) rules when effecting over-the-counter (OTC) trades in equity securities on a “net” basis.
FINRA Regulatory Notice 18-28 FINRA Requests Comment on a Proposal to Expand OTC Equity Trading Volume Data Published on FINRA’s Website
FINRA requests comment on a proposal to expand the summary firm data relating to over-the-counter (OTC) equity trading that FINRA publishes on its website by (1) publishing on a one-month delayed basis new monthly aggregate block-size trading data for OTC trades in NMS stocks executed outside an alternative trading system (ATS); (2) publishing aggregate non-ATS volume for all firms, by eliminating the existing de minimis exception; and (3) separately identifying firms’ volume of trading on a single dealer platform (SDP), by requiring firms to use a unique market participant identifier (MPID) when reporting their SDP trades to FINRA.
MSRB Regulatory Notice 2018-22 Request for Comment on Draft Interpretive Guidance on Pennying and Draft Amendments to Existing Guidance on Best Execution
The MSRB is seeking comment on draft interpretive guidance related to “pennying” and draft amendments to existing guidance on best execution relating to the posting of bid-wanteds on multiple trading platforms. In addition, as part of its ongoing review of its rules, the MSRB also seeks comment as to whether there are other secondary market trading practices that could benefit from additional regulatory guidance or clarity, or whether there are any MSRB requirements related to secondary market trading practices that commenters may feel are no longer necessary and could be removed from and/or amended in MSRB rules.
FINRA Regulatory Notice 18-26 FINRA Requests Comment on Enhancements Under Consideration by the Securities Industry/Regulatory Council on Continuing Education
FINRA requests comment from member firms and other interested parties on enhancements to the Securities Industry Continuing Education Program (CE Program) under consideration by the Securities Industry/Regulatory Council on Continuing Education (CE Council). These enhancements include the transition of the Regulatory Element program to a more focused and shorter learning requirement administered annually. The CE Council is also gathering feedback on the current Firm Element program and supporting resources as well as on the overlap of the Firm Element program with other firm training requirements. The overall goal of the program review is to reflect advances in technology and learning theory while continuing to ensure that registered persons receive timely education on the securities business and the regulatory requirements applicable to their respective functions. In addition, the CE Council is exploring program changes that would allow individuals to maintain their qualification status following the termination of their registrations by completing continuing education in an effort to address the challenges that industry professionals face when attempting to re-enter the industry after an absence.
ffective October 1, 2018, FINRA is restructuring its representative-level qualification examination program. As part of this restructuring, FINRA has developed the Securities Industry Essentials™ (SIE™) examination and revised several of its representative-level qualification examinations. In addition, FINRA has (1) set the fee for the SIE examination; (2) revised the fees for the representative-level examinations that FINRA is retaining; and (3) revised the administration and delivery fee for the Municipal Securities Representative (Series 52) examination. The text of the amendments to Section 4(c) of Schedule A to the FINRA By-Laws relating to examination fees is set forth in Attachment A. The new and revised qualification examination fees will apply for examination requests made on or after October 1, 2018.
Cboe Options Regulatory Circular 18-030 Consolidated Audit Trail – Industry Member Technical Specifications
Today CAT NMS, LLC published version 0.6 of the CAT Reporting Technical Specifications for Industry Members (“IM Technical Specifications”) for Industry Member reporting to the CAT. The IM Technical Specifications are available on the CAT NMS Plan website. This version of the IM Technical Specifications represents the last draft version that will be published for industry comment before the release of the final IM Technical Specifications, targeted for October 30, 2018.
MSRB Regulatory Notice 2018-20 Request for Information on the Accessibility, Methodology and Utility of Indices, Yield Curves and Other Benchmarks
The MSRB is requesting information from market participants and the public on the accessibility, methodology and utility of indices, yield curves and other benchmarks currently available in the municipal market. The purpose of this notice is to obtain information and insight from commenters to inform and support the MSRB’s mission to promote a fair and efficient municipal market. This request is a continuation of the MSRB’s interest in the use and availability of benchmarks in the municipal securities market and is intended exclusively to inform the MSRB. The MSRB does not have regulatory jurisdiction in this area, and this request is not a precursor to initiating rulemaking. Comments should be submitted no later than November 27, 2018 and may be submitted in electronic or paper form.
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