MSRB approves guidance filing to clarify dealer obligations under municipal disclosure rules

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MSRB dealer obligations guidance

Highlights

MSRB approved filing interpretive guidance with the SEC to clarify Form G-32 submission and new issue reporting under Rule G-34.
The board continued reviewing Rule G-37 amid the SEC's proposal to rescind its pay-to-play rule for investment advisers and deferred action on retiring financial advisory terminology.
Ongoing technology upgrades focus on cybersecurity, data handling, and transparency systems, driven by growth in municipal market volume and advances in AI.

Board actions on rules and supervision

As reported by the Municipal Securities Rulemaking Board, the board approved the filing of interpretive guidance with the SEC to clarify submission processes and timelines associated with Form G-32 and the new issue information required under Rule G-34.

The board also reviewed other regulatory matters as part of its retrospective rule review process. These included the status of the dealer supervision modernization initiative, possible next steps based on stakeholder feedback and municipal market-specific needs, and FINRA's request for comment on potential amendments to Rule 2210 governing communications with the public.

In addition, the board continued its review of Rule G-37 in light of the SEC's proposal to rescind its pay-to-play rule for investment advisers. It also reviewed comments on a proposal to retire certain financial advisory terminology and deferred any rule amendments on that issue until a later phase of the retrospective review.

Technology upgrades and market transparency focus

Board Chair Alexander Chilton said the rule review effort must modernize the MSRB rule book while preserving core protections for investors, issuers and the public interest. He also said continued growth in municipal market volume and advances in AI make it critical for the MSRB to upgrade the systems that receive, store and distribute market data.

Separately, the board received updates on information technology and market transparency systems as part of an ongoing technology transformation and systems modernization project. Those efforts include cybersecurity enhancements, upgrades to secure data handling, research and analysis on the municipal market, and expanded stakeholder engagement opportunities through the next fiscal year.

Our earlier article on banks’ cyber resilience highlighted regulators’ push for deeper recovery planning as AI increases the scale and complexity of cyber threats to the financial system. It explained why supervisors are urging major lenders to develop independent “bare metal” recovery options for critical services and to strengthen end-to-end operational resilience, not just perimeter defenses.

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