The Bond Market Association (TBMA) provides comments to the Municipal Securities Rulemaking Board (MSRB) on draft procedures for reporting special condition indicators for certain special trading situations of transactions reported to the MSRB’s Real-time Transaction Reporting System (RTRS), MSRB Notice 2006-20.  TBMA believes that many of the proposed changes would create issues such as double-counting of trades, reporting of trades which occur at an off-market price by design and reporting of variable rate and auction rate securities which necessarily trade at par.

*SIFMA is a product of the merger between the Securities Industry Association (SIA) and the Bond Market Association (TBMA) in 2006.