While the SEC, the MSRB
, and others in Congress look at potential options to address "timely" financial reporting, GFOA will continue to update the best practices and advisories that help ensure an audit process that produces reliable data for all stakeholders.
(45) Since the SEC has the power to broker-dealers and municipal securities dealers, they have caused back-door regulation through Exchange Act Rule 240.15c2-12, SEC interpretations, enforcement of the antifraud provisions of the federal securities laws, and Commission oversight of the MSRB
In addition, new MSRB
and Financial Industry Regulatory Authority mark-up disclosure rules, which took effect in May 2018, generally require dealers to disclose to investors in the fixed income markets many of whom are retail investors the mark-up or mark-down charged on certain principal transactions in municipal and other debt securities.
These issues were reported as missing in the data from the Missouri State Auditor, and we were unable to locate them on the Municipal Securities Rulemaking Board (MSRB
) on-line EMMA system.
the banks that pitched CABs may have violated the MSRB
Likewise, the antimicrobial drug resistance genes (mecA, msrA, msrB
, ermA, ermB, ermC and blaZ) were determined.
529 plans are classified as municipal fund securities and are governed by the rules of the Municipal Securities Rulemaking Board MSRB
(1) For purposes of this paper, the federal financial regulators affected by Dodd-Frank include the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Federal Housing Finance Agency (FHFA), Federal Insurance Office (FIO), National Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), Bureau of Consumer Financial Protection (CFPB), Financial Stability Oversight Council (FSOC), and Office of Financial Research (OFR), as well as the quasi-governmental regulators: the Public Company Accounting Oversight Board (PCAOB), Municipal Securities Rulemaking Board (MSRB
), and National Futures Association (NFA).
15, 2012) (stating the mission of MSRB
is "[t]o establish and improve standards of state and local governmental accounting and financial reporting that will: [r]esult in useful information for users of financial reports, and [g]uide and educate the public, including issuers, auditors, and users of those financial reports").
SIB intermediaries would appear to fall under the definition of "municipal securities broker[s]" in section 15B of the 1934 Act, which defines that term as a "broker engaged in the business of effecting transactions in municipal securities for the account of others." (119) Such brokers must register with the SEC (120) and are governed by the Municipal Securities Rulemaking Board (MSRB
Unlike stocks, mutual funds and ETFs, municipal bonds aren't heavily regulated, but rather, governed by a self-regulatory organization (SRO) called the Municipal Securities Rulemaking Board or MSRB
. Despite all of the benefits that SROs like the MSRB
may have, strictly enforced rules and rigorous disclosures aren't among them.
In reviewing muni regulation recently, the US Securities and Exchange Commission last week criticized the municipal market, citing its illiquidity and lack of transparent pricing information and indexes for market data, including those prepared by Thomson Reuters (the company is working with the SEC and Municipal Securities Rulemaking Board (MSRB