RTRS Reporting: Municipal Trades to the MSRB Within 15 Minutes

ByRegReportingDesk
RegReportingDesk card: MSRB, Municipal Securities Rulemaking Board, United States

RTRS reporting is the duty, set by MSRB Rule G-14, for every broker, dealer and municipal securities dealer to report each purchase and sale of a municipal security to the Municipal Securities Rulemaking Board’s Real-Time Transaction Reporting System (RTRS). From 1 July 2026 the Rule G-14 RTRS Procedures require a trade executed during the RTRS Business Day to be reported as soon as practicable and no later than 15 minutes after the Time of Trade, and Supplementary Material .01 to Rule G-14 requires dealers to adopt policies and procedures reasonably designed to meet that standard. RTRS disseminates price and volume information in real time, publicly through the MSRB’s EMMA website and subscription feeds, and the same records sit in the audit trail that examiners use.

The stakes are written into paragraph (a)(iv) of the RTRS Procedures, as amended with effect from 1 October 2025: a report that misses its timeframe is designated late, and a pattern or practice of late reporting without exceptional circumstances or reasonable justification may be considered a violation of the rule. MSRB Notice 2005-02 of 10 January 2005 still explains Time of Trade well, but it describes a transition that ended long ago. Its three-hour allowance for dealers that had not traded an issue in the previous year was framed as a first-year measure; the MSRB’s own RTRS Specifications record that a three-hour deadline for certain trades sunset on 29 December 2006, and no three-hour exception appears in the current RTRS Procedures.

Related reading: UK Bond Consolidated Tape: What Real-Time Transparency Means for Post-Trade Reporting Under UK MiFIR

The MSRB writes its rules under Section 15B(b)(2) of the Securities Exchange Act of 1934, which provides that the Board shall propose and adopt rules with respect to, among other matters, transactions in municipal securities effected by brokers, dealers and municipal securities dealers. Congress established the MSRB in 1975; it is a self-regulatory organization overseen by Congress and the Securities and Exchange Commission, and it files its rule changes with the SEC under Section 19(b) of the Exchange Act. Rule G-14, titled “Reports of Sales or Purchases”, works in three layers:

  • Rule G-14 itself. Paragraph (a) bars a dealer from distributing or publishing a report of a purchase or sale of municipal securities unless it knows or has reason to believe the trade was actually effected. Paragraph (b) carries the reporting duty: each dealer reports information about each purchase and sale transaction effected in municipal securities to RTRS, in the manner set out in the RTRS Procedures and the RTRS Users Manual.
  • The Rule G-14 RTRS Procedures. They name the three RTRS portals in paragraph (a)(i), set the timing rules in (a)(ii) to (a)(iv), govern inter-dealer, customer and inter-dealer regulatory-only trades in section (b), and hold the definitions in section (d), including Time of Trade in (d)(iii) and the RTRS Business Day in (d)(ii).
  • The RTRS Users Manual. Paragraph (c) of the Procedures defines it as the Specifications for Real-Time Reporting of Municipal Securities Transactions, the Users Guide for RTRS Web, the MSRB’s guidance on reporting specific types of transactions and other information relevant to reporting under Rule G-14. The Specifications, currently version 4.1 of November 2022, and the RTRS Web Manual, version 3.9 of October 2025, are therefore part of the compliance perimeter.

Two companion instruments complete the chain. Rule G-12(f)(i) requires inter-dealer transactions eligible for comparison by a clearing agency registered with the SEC to be compared through that clearing agency, and the RTRS Web Manual confirms that reporting an inter-dealer trade through the Real-Time Trade Matching (RTTM) environment satisfies the Rule G-14 requirement for that trade. Information Facility IF-1 describes how RTRS measures lateness: it compares the Time of Trade reported by the dealer with the timestamp assigned by RTTM or RTRS on receipt.

One passage in Notice 2005-02 addresses the gap between comparison and reporting. A record good enough to compare at the National Securities Clearing Corporation (NSCC) can fail Rule G-14 if the MSRB-only fields are missing: the time of trade, the Effecting Broker Symbol for both sides, and each dealer’s capacity as agent or principal. The MSRB described the omission of those items on inter-dealer reports as a violation of Rule G-14.

The RTRS Web Manual gives the system two purposes, price transparency and a surveillance audit trail for enforcement agencies, and one RTRS report serves both. MiFIR splits them: Article 26 transaction reports go to the competent authority (see our MiFIR transaction reporting guide), while public post-trade data runs through separate arrangements such as the OTC derivatives consolidated tape.

Who must report to RTRS: every dealer, with clearing brokers carrying the IDRO leg

Rule G-14(b) applies to each broker, dealer or municipal securities dealer, which brings bank dealers into scope alongside broker-dealers. Each dealer must obtain a unique broker symbol from NASDAQ Subscriber Services to identify its transactions (Rule G-14(b)(iii)), and the RTRS Web Manual states that NASDAQ assigns executing broker symbols to all dealers, bank dealers included. Rule G-14(b)(iv) disapplies the reporting section to a dealer that effects no municipal securities transactions, or only the transactions that Rule G-14(b)(v) excludes, and that has confirmed its qualification for the exemption as provided in Rule A-12.

Every dealer reports on the same clock regardless of volume. The 2024 amendments contained a size-based carve-out for dealers with “limited trading activity” (fewer than 2,500 purchase or sale transactions reported to an RTRS Portal in at least one of the prior two consecutive calendar years), and the 2025 amendments deleted it before it ever applied.

Three categories of transaction stay out of RTRS altogether under Rule G-14(b)(v):

  • transactions in securities without assigned CUSIP numbers;
  • transactions in municipal fund securities;
  • inter-dealer principal movements of securities between dealers that are not eligible for comparison through a clearing agency.

Within scope, the filer depends on the trade type:

  • Inter-dealer trades eligible for comparison are generally reported through the registered clearing agency’s comparison process, and the transaction records also serve Rule G-14 reporting. For bilateral submissions, each dealer submits or causes the required transaction record to be submitted; for unilateral submissions deemed compared upon submission by one side under the clearing agency’s rules, the contra-side need not make a separate submission but must monitor the submission and use the clearing agency’s procedures to correct inaccurate data representing its side.
  • Customer trades. The dealer reports the transaction information specified for customer transactions in the RTRS Specifications. A dealer may report directly or use an authorised intermediary, while primary responsibility for timely and accurate submission remains with the dealer that effected the transaction.
  • Inter-dealer regulatory-only (IDRO) trades. When an introducing broker effects a customer trade against the principal position of its clearing broker, the clearing broker reports an IDRO transaction showing that it sold as principal to the introducing broker, which acted as agent, and the introducing broker causes a customer report to be sent showing that it effected the sale as agent. The RTRS Web Manual states that only clearing brokers can report or update IDRO trades.

A dealer may submit through its clearing broker or a service bureau. The RTRS Web Manual is plain that the primary responsibility for timely and accurate submission remains with the dealer that effected the transaction, while a dealer that submits inter-dealer trades for comparison, for itself or for another dealer, is responsible for the parts of the comparison process under its control.

The MSRB sources reviewed for this explainer say nothing about consolidation, branches or third-country firms. The reporting unit they describe is the individual transaction and the dealer that effected it, and none of them describes a group-level or consolidated submission.

What the report contains: MT515 fields, capacity and the special condition indicator

Each RTRS report is a single message for a single trade, and section 4.2.2 of the Specifications tabulates, field by field, whether a data element is mandatory, omitted or used when applicable for inter-dealer, IDRO and customer trades. The fields that carry the regulatory content are:

  • Trade date and Time of Trade, mandatory on every trade type and entered to the second (RTRS Web takes 24-hour Eastern Time, hh:mm:ss); the Specifications allow the seconds to be entered as 00 where the submitter’s system cannot report seconds or the time to the second is not known. A modification may move the time earlier than the original instruct message, never later.
  • CUSIP (nine characters) and par. Par is the face amount, never units. Customer and IDRO par may include cents (the Specifications give 826,186.23 as a valid amount); inter-dealer par must be in whole dollars, and an inter-dealer par of 1,000 or more must be a multiple of 1,000, so a par of 100,700 is submitted as two transactions of 100,000 and 700.
  • Deal price, reported as a dollar price, or as a yield only for when-issued trades effected on a yield basis; inter-dealer regular-way trades report the settlement amount instead of a deal price (section 4.3.1 of the Specifications). Since the 2016 changes, the MSRB calculates yield on customer trades instead of dealers reporting it.
  • Buy/sell indicator and capacity. Rule G-14 requires a dealer to report whether it acted as principal or as agent. On a customer report the capacity is mandatory on the dealer side and omitted on the customer side; on an IDRO the clearing broker reports itself as principal and the correspondent as agent.
  • Commission on customer agency trades, entered on the MT515 as a dollar amount for the trade and as a positive number on both buys and sells.
  • Settlement date, accrued interest and settlement amount. For inter-dealer final-money trades, accrued interest is reported, as zero where it is calculated as zero or cannot be calculated, and the Regulatory Dollar Price is mandatory.
  • The dealer control number (X-REF), limited to 16 printable ASCII characters; market of execution “OTMU” on every trade; a trade transaction type of “CASH” for customer trades and “TRLK” for IDROs; and a destination of “MSRB” for customer and IDRO reports.

Field sizes follow the RTTM maxima where they are smaller than the SWIFT format allows, and the Specifications require input to meet whichever of the NSCC, RTTM and RTRS format restrictions is most stringent for a given field.

The special condition indicator (field SPXR) is a four-character code in the form Mccc. The Specifications assign each variable position to a different category of condition: price conditions in the second position, deadline exceptions and late inter-dealer conditions in the third, and trade-type flags in the fourth. M9cc, the away-from-market (other reason) indicator, is required where the price differs substantially from the market price for multiple reasons or for a reason no other special condition indicator covers, and it applies to both legs of a bona fide customer repurchase agreement (see the FAQ below) as well as to unit investment trust deposits from an accumulation account and tender option bond program transfers.

Paragraph (b)(iv) of the RTRS Procedures, reorganised from 1 October 2025, splits the special condition indicators into two groups regardless of the specific code assigned to each. Indicators that Section 4.3.2 of the Specifications designates as optional, such as the one for a short-term instrument or for the resubmission of an RTTM cancel, are “conditionally optional”: required only to obtain the corresponding extended deadline, and omissible if no extension is claimed. Indicators for a List Offering Price/Takedown Transaction, an away-from-market trade, a VRDO ineligible on trade date, a bond traded flat, an ATS-executed inter-dealer trade and a non-transaction-based compensation arrangement are mandatory whether or not an extended deadline is sought, so the List Offering Price/Takedown indicator goes on the report even when the trade is reported inside 15 minutes.

RTRS deadlines: 15 minutes, as soon as practicable and the end-of-day exceptions

RTRS reporting is event-driven: each trade starts its own clock at the Time of Trade, so the reference dates, reporting periods and remittance calendars of periodic returns have no RTRS equivalent, and there is no first or next reference date to diarise. Real-time reporting has applied since 31 January 2005, and the as-soon-as-practicable standard has applied since 1 July 2026. The operative timings are:

  • RTRS Business Day: 7:30 a.m. to 6:30 p.m. Eastern Time, Monday to Friday, unless otherwise announced by the MSRB (RTRS Procedures (d)(ii)).
  • Standard deadline: as soon as practicable, and no later than 15 minutes after the Time of Trade, for a trade executed during the RTRS Business Day (paragraph (a)(ii)).
  • Trades outside the RTRS Business Day, and inter-dealer trades on an invalid RTTM trade date: no later than 15 minutes after the beginning of the next RTRS Business Day (paragraph (a)(iii)).
  • List Offering Price/Takedown Transactions and away-from-market trades: by the end of the day on which the trade is executed (paragraphs (a)(ii)(A)(1) and (3)).
  • Short-term instruments maturing in nine months or less, variable rate instruments that may be tendered at least every nine months, auction rate products with auctions at least every nine months, and commercial paper maturing or rolling over in nine months or less: by the end of the RTRS Business Day on which the trade was executed (paragraph (a)(ii)(A)(2)).
  • Inter-dealer “VRDO ineligible on trade date”: by the end of the day on which the trade becomes eligible for automated comparison (paragraph (a)(ii)(B)(1)).
  • Inter-dealer resubmission of an RTTM cancel: identical information by the end of the RTRS Business Day following the day the trade was cancelled (paragraph (a)(ii)(B)(2)).
  • Modification or cancellation of customer and IDRO trades: up to 24 months after trade date, according to the Specifications.

The as-soon-as-practicable requirement applies only to trades on the 15-minute clock. MSRB Notice 2025-05 of 17 September 2025 states that it does not reach trades reported under an exception from that timeframe. Supplementary Material .01(a) adds the behavioural rule: a dealer must not purposely withhold trade reports, for example by programming its systems to delay reporting until the last permissible minute. Where a dealer has reasonably designed policies, procedures and systems, a delay caused by extrinsic factors that were not reasonably predictable, such as a systems outage, generally will not be viewed as a violation, provided the dealer did not purposely intend the delay.

Time of Trade is defined in paragraph (d)(iii) as the time at which a contract is formed for a sale or purchase of municipal securities at a set quantity and set price. Notice 2025-05 repeats the rule from 2005: the time of execution is reported, even where the trade is keyed into the processing system later. The same applies after hours, where the dealer reports when the trade was executed, not when the report is made.

The 2025 notice also settles a question the definition leaves open. Where an order cannot be executed until the trader completes supervisory or firm-mandated reviews (risk and compliance limits, best execution, suitability or fair pricing checks) that could change the price or quantity, the dealer may reasonably determine that the meeting of the minds occurs only once those processes are complete and it has affirmatively accepted the order. The MSRB expects the dealer to be clear with the counterparty about the final terms and to reflect the processes in its written policies and procedures; the parties may also expressly agree a Time of Trade consistent with when the contract binds them.

Submission of RTRS reports: NSCC messages, RTTM Web and RTRS Web

Paragraph (a)(i) of the RTRS Procedures designates three RTRS Portals, which Notice 2025-05 summarises as follows:

  • the Message Portal, used for trade submission and modification by message through NSCC;
  • the RTRS Web Portal, used for low-volume transaction submission and modification;
  • the RTTM Web Portal, used only for inter-dealer transactions eligible for automated comparison.

The message route uses ISO 15022 SWIFT-based messages. The MT515 carries the trade input (instruct, modify, cancel or DK), and the MT509 carries the responses: trade accepted and trade matched from RTTM, and error messages or an affirmation from RTRS. The Specifications also cover MT518 and MT599 messages. Submitters send messages to the NSCC Access Network, which relays them to and from RTRS; NSCC forwards customer trades to the MSRB without processing them in comparison. Once a portal has the report, the Specifications put error checking and dissemination at no more than 90 seconds.

Readers used to XBRL or XML filings will find no taxonomy, schema version or file-naming convention in the RTRS sources, because the unit of submission is a single trade message. The files dealers download from RTRS Web, its exports and reports, come as Excel (.xlsx).

Hours matter for the web routes. Paragraph (a)(vi) of the RTRS Procedures opens the RTRS Portals from 30 minutes before the start of the RTRS Business Day until 90 minutes after its end, while the RTRS Web Manual describes RTRS accepting and disseminating trade reports received between 6:00 a.m. and 9:00 p.m. Eastern Time, with reports submitted after 9:00 p.m. pended for processing and dissemination at 6:00 a.m. on the next business day. Access to RTRS Web runs through MSRB Gateway.

Resubmission and correction rules sit in the processing indicators of the Specifications:

  • An Instruct is sent once for each X-REF while the trade is stored in RTTM or RTRS. RTRS accepts an Instruct for a trade date of 2 January 2002 or later but marks it late if the deadline has passed.
  • A Cancel on an inter-dealer trade is possible only before RTTM has matched it; a customer or IDRO trade can be cancelled up to 24 months after trade date. RTRS Web cancels customer and IDRO trades only, and the RTRS Web Manual states that inter-dealer trades may only be cancelled via FICC.
  • A Modify on an inter-dealer trade can change any field except CUSIP and market of execution before the match; after the match only the X-REF and the regulatory fields can be modified.
  • The Specifications prohibit reusing an X-REF value within a set period; RTRS sends an error requiring a reused X-REF to be changed.
  • Inter-dealer trade submissions go to both RTTM and RTRS, and the error list includes “interdealer submission must be sent to both RTTM and RTRS”. The RTTM-only destination is the route for comparison-only submissions such as step-out deliveries, which RTRS stores as Destination Code 01 only.

Validation in RTRS: error code families, late flags and the monthly data quality reports

Validation runs in two stages for inter-dealer trades. RTTM checks the comparison data first, and an inter-dealer trade rejected by RTTM is not accepted by RTRS, so RTTM rejects have to be cleared before any RTRS message arrives. RTRS then returns MT509 messages carrying an error code, and each code carries a severity that tells the dealer what action it calls for.

Error codes fall into two broad categories in practice. Some flag a submission the dealer can still put right, by modifying it, cancelling and replacing it, or reviewing and confirming the data. Others flag a report RTRS has already scored late, a status that cannot be corrected into a timely one after the fact: N913 is the late-trade code a dealer sees in RTRS Web when a report has missed its deadline.

Paragraph (a)(iv) of the RTRS Procedures requires untimely or inaccurate data to be submitted or corrected as soon as possible, and the Specifications quote paragraph (a)(v): status information indicating a problem must be reviewed and addressed promptly.

Section 2.9 of the Specifications lists the messages by data field. A selection shows where the checks bite: a time of trade before 0600 or after 2100, or in the future; par reported in units; a commission above 10 percent of the dollar price, or on a principal trade; no accrued interest on a trade not flagged as traded flat; an invalid CUSIP; unknown dealer and submitter combinations; an ATS indicator on a customer trade; and a modify or cancel received more than two years after trade date.

Rejected messages are a separate queue from error codes. The RTRS Web Manual gives the classic case: a modify message for a customer trade whose original instruct cannot be found from the control numbers provided is rejected and shows on the Rejected Messages screen, where it has changed nothing. The Specifications also list an unparsable MT515 message among the error conditions.

Matched inter-dealer trades get a second round of checks against the contra side, reported in the RTRS Web Discrepancy Error Code Report: Q19F where accrued interest differs between buyer and seller, Q22F where the two times of trade differ by more than 15 minutes, Q33F where the Regulatory Dollar Prices differ, and Q55A where the ATS indicators differ. Price Variance Alerts add a third layer. The MSRB emails a firm when a reported price is markedly different from other dealers’ prices in the same security over the same period, and the manual states that prices the firm does not modify will be considered accurate.

The RTRS Dealer Data Quality reports close the loop. They are available on or about the first business day after the 15th of each month, cover transactions reported in the preceding month plus changes made in the 15 days after month-end, and set the firm’s figures against its prior period and the industry. The Excel versions, the manual notes, use the format made available to FINRA examiners.

Caveats for RTRS filers: manual workflows, allocations, step-outs and the TRACE boundary

Proportionality in RTRS reporting works through supervision. Supplementary Material .01(b) expects the regulatory authorities that examine dealers to take the manual nature of a dealer’s trade reporting process into account when judging whether its policies and procedures are reasonably designed to report as soon as practicable. None of the MSRB sources reviewed here describes a waiver process.

Late reports get a facts-and-circumstances test. Notice 2025-05 gives three examples of exceptional circumstances or reasonable justification: failures of MSRB, third-party or internal systems outside the dealer’s reasonable control, extreme volatility, and a bid list with too many distinct securities to report in time. Recurring systems issues in a dealer’s or a vendor’s systems will not excuse a pattern, and dealers bear the burden of proof. Dealers can document outages through the Dealer System Outage Report process in MSRB Gateway; the MSRB’s 2025 filing says those reports go to the authorities that enforce MSRB rules.

The MSRB expects examiners to focus on the consistency of timely reporting and on effective controls, rather than on individual late outliers, while keeping open action on a single late report that was intentional or egregious or raises fair practice, fair pricing or best execution concerns.

Three reporting boundaries recur in MSRB guidance:

  • Step-out deliveries. Notice 2005-02 defines a step-out delivery as a transfer of securities between dealers through NSCC’s comparison system that is not the result of a purchase-sale transaction, for example when an investment adviser tells the selling dealer to deliver to an account held at another dealer. Reporting it to the MSRB as an inter-dealer trade violates Rule G-14, and so does using the step-out procedure for a genuine purchase-sale.
  • Block allocations by dually registered broker-dealer/investment advisers. Interpretive guidance of 5 September 2025 confirms that where such a firm buys a block and allocates it internally to advisory accounts at the block price without transaction-based compensation, only the original block order is reported. The MSRB’s reasoning is that allocation prices set off a larger block would not indicate market prices and could mislead.
  • New issues before award. Dealers may take orders and make conditional commitments, but Notice 2025-05 restates that a when-issued trade cannot be executed, confirmed or reported before the issue is formally awarded.

The overlap with FINRA’s TRACE is narrower than the similar wording suggests. FINRA Rule 6710(a) defines a TRACE-Eligible Security by four categories: private-issuer debt, Agency and Government-Sponsored Enterprise debt, US Treasury Securities and Foreign Sovereign Debt Securities. Municipal securities are not among them, so a desk’s municipal trades go to RTRS and its corporate or agency trades to TRACE. FINRA Rule 6730(a) uses near-identical language (“as soon as practicable, but no later than within 15 minutes of the Time of Execution”), and the MSRB cited that alignment when it kept the as-soon-as-practicable standard. The details differ. TRACE takes List or Fixed Offering Price and Takedown Transactions by the next business day under Rule 6730(a)(2), where RTRS wants them by the end of the trade day, and TRACE’s Time of Execution in Rule 6710(d) turns on agreement to terms sufficient to calculate the dollar price, where RTRS’s Time of Trade turns on a set quantity and set price.

The transitional provisions ran in two stages. The clarifying and technical amendments took effect on 1 October 2025, and the MSRB stated that the substantive 15-minute requirement and all the existing exceptions continued to operate without interruption across that date; the as-soon-as-practicable, policies and procedures and Rule G-12(f) comparison changes followed on 1 July 2026.

Changes to RTRS reporting: the one-minute rule that never applied and the 2026 standard

  • 31 January 2005: full real-time transaction reporting begins, on a 15-minute standard (Notice 2005-02).
  • July 2016: the RTRS Specifications (version 2.9) reflect MSRB Notices 2015-07 and 2016-09, extending the List Offering Price/Takedown indicator to distribution participants and to takedowns not at a discount, ending dealer-reported yield on customer trades and adding the non-transaction-based compensation and ATS indicators.
  • 20 September 2024: the SEC approves the one-minute amendments (Exchange Act Release No. 101118), with exceptions for dealers with limited trading activity and for trades with a manual component, the latter phased from 15 to 10 to 5 minutes over three calendar years. The MSRB never set an effective date.
  • March 2025: the MSRB Board authorizes further amendments to Rule G-14.
  • 10 June 2025: the MSRB files SR-MSRB-2025-01 to rescind the one-minute deadline, delete the two new exceptions and the manual trade indicator, and keep the as-soon-as-practicable requirement.
  • 16 September 2025: the SEC approves SR-MSRB-2025-01 (Exchange Act Release No. 103987, published at 90 FR 45274 on 19 September 2025); the MSRB announces the approval in Notice 2025-05 on 17 September 2025.
  • 1 October 2025: clarifying and technical amendments take effect, covering the renumbered exceptions, the late designation and pattern-or-practice language, the invalid RTTM trade date rule in paragraph (a)(iii), the reorganised special condition indicators in paragraph (b)(iv) and the IF-1 lateness wording.
  • 1 July 2026: the as-soon-as-practicable reporting requirement, Supplementary Material .01 and the as-soon-as-practicable submission for comparison under Rule G-12(f) take effect.

The MSRB’s stated reasons for dropping one minute are specific. Its trade data showed the share of trades reported within 15 seconds rising from 24.8% to 34.2% between 2022 and 2024, and the share within 30 seconds from 52.7% to 56.7%, while market participants raised implementation problems with manual and hybrid workflows and with some fully automated trades that depend on vendors and market utilities. The MSRB estimated the retained standard at USD 6,246 of upfront policy and training cost per dealer and USD 1,179 a year in ongoing compliance cost, and said it intends to keep monitoring reporting times and publish its findings. The sources set no date for a further change to the reporting timeframe.

One adjacent filing, SR-MSRB-2026-01, was filed with the SEC on 1 May 2026 to amend Rule G-12(c) confirmation requirements for inter-dealer municipal securities transactions ineligible for automated comparison, a population the SEC’s approval order describes as predominantly securities that lack an assigned CUSIP number. The SEC approved the proposed rule change on 17 June 2026 (Release No. 34-105714), and MSRB Notice 2026-08 of 3 September 2026 sets 1 August 2027 as the effective date of the amended Rule G-12(c). For a European comparison of how supervisors are recalibrating reporting burdens, see our note on ESMA’s transaction reporting simplification plan.

Frequently Asked Questions

A trade is executed at 6:25 p.m. Eastern Time. Is it due by 6:40 p.m. or the next morning?

Paragraph (a)(ii) keys the deadline to a Time of Trade during the RTRS Business Day and contains no carve-out for trades near the 6:30 p.m. close. My reading is that the report is due by 6:40 p.m., which falls inside the RTRS Portal hours in paragraph (a)(vi), since the portals stay open until 90 minutes after the 6:30 p.m. close. FINRA Rule 6730(a)(1)(C), by contrast, expressly moves TRACE trades executed less than 15 minutes before its close to the next business day.

How are weekend trades handled?

A customer trade executed outside the RTRS Business Day is reported within 15 minutes after the next RTRS Business Day begins, with the actual Time of Trade. Inter-dealer trades on a weekend or holiday that is not a valid RTTM trade date follow the same deadline, but the Specifications require the report to carry the next earliest valid trade date and time together with the special condition indicator for a trade ineligible on trade date.

When does the clock start on a new issue sold from pre-sale orders?

At the formal award. Notice 2005-02 defines the time of formal award as the signing of the bond purchase agreement for a negotiated issue and the official award by the issuer for a competitive issue. The MSRB has characterised pre-sale orders as expressions of firm intent that may only be executed on the award of the issue or the execution of a bond purchase agreement.

A trade from last week was never reported. What now?

Report it as soon as possible under paragraph (a)(iv). RTRS will accept the Instruct and mark it late, and the late designation cannot be removed by later correction. The rule’s violation language targets a pattern or practice of late reporting, which is why the circumstances and the remediation are worth recording when the miss is found.

Do both legs of a customer repurchase agreement get reported?

Yes. The Specifications require both the sale and the repurchase arising from a bona fide customer repo to carry the M9cc away-from-market indicator, which also gives each leg the end-of-day deadline. Unit investment trust deposits from an accumulation account and tender option bond program transfers take the same indicator.

Are when-issued short-term notes always reportable between dealers?

Not necessarily. The Specifications record the MSRB’s understanding that all issues with assigned CUSIPs are RTTM-eligible except when-issued short-term notes that pay interest at maturity and lack a 30/360 day count, and that inter-dealer trades in an issue that is not RTTM-eligible are not subject to the reporting requirement. Customer trades in the same notes remain reportable if a CUSIP is assigned, and the Specifications direct dealers to NSCC for formal eligibility statements.

Our desk already follows FINRA’s as-soon-as-practicable standard for TRACE. Does Rule G-14 need its own procedures?

Supplementary Material .01(a) requires procedures reasonably designed to comply with the Rule G-14 standard. The MSRB’s cost analysis expected firms that trade other fixed income securities to adapt their existing compliance programmes, so extending a TRACE procedure is contemplated. My reading is that the extended procedure still has to address the RTRS specifics: Time of Trade as defined in paragraph (d)(iii), the special condition indicators and the RTRS error codes.

Key Takeaways

  • Adopt the Supplementary Material .01 policies and procedures (in force since 1 July 2026) and make them evidence systems that start the reporting process without delay on execution.
  • Stamp the Time of Trade at contract formation and document any pre-acceptance review steps in the written procedures before relying on them.
  • Attach every mandatory special condition indicator even when the trade is reported inside 15 minutes; the extended deadline exists only if the indicator is on the report.
  • Treat a correctable error code as same-session work; a late-designated report cannot be corrected into a timely one, so the control that matters sits upstream of the report.
  • Reconcile the Dealer Data Quality reports each month after the 15th against internal late-trade logs and open discrepancy codes.
  • Log system outages through the MSRB Gateway Dealer System Outage Report process when they happen; the dealer carries the burden of proving exceptional circumstances.

Sources and References

What an RTRS desk file should hold

Because the MSRB has pointed examiners at the consistency of timely reporting and at controls, the evidence for RTRS reporting under the July 2026 standard is documentary. The file should hold the Supplementary Material .01 policies and procedures, including any pre-acceptance review steps that affect Time of Trade, and a map from each trade type the desk runs to its deadline and special condition indicator. Next to them sit the monthly Dealer Data Quality reconciliations and the outage reports filed through MSRB Gateway. The next Dealer Data Quality report lands on or about the first business day after the 15th; reconciling it against the desk’s own late-trade log is the first job on that day.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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