Letters

MSRB Rule G- 34(a)(i) on the Use of CUSIPs

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) regarding the recently proposed amendments to MSRB Rule G-34, on obtaining CUSIP numbers, which aim to clarify existing requirements and improve market consistency. If approved, the rule would codify the MSRB’s interpretation that municipal securities dealers are required to obtain CUSIP numbers for new issue securities sold in private placement transactions, including direct purchases. Additionally, if approved, non-dealer municipal advisors advising on competitive offerings would be required, like dealer municipal advisors under the current rule, to apply for CUSIP numbers. The MSRB’s proposal includes a principles-based exception from the requirement to obtain CUSIP numbers for direct purchases of municipal securities by banks – as well as their non-dealer control affiliates – that are intended to be held to maturity.

See also:
MSRB Filing

Federal Register

PDF

Submitted To

SEC

Submitted By

SIFMA

Committee

Municipal Securities Division

Date

10

October

2017