MSRB G-32 Late Initiation Report Card
The MSRB G-32 Late Initiation Report Card is a monthly status report card intended to help firms evaluate the timeliness of their initiations of Form G-32 pursuant to Municipal Securities Rulemaking Board (MSRB) Rule G-32(b)(vi)(C).
According to MSRB Rule G-32(b)(vi)(C)(1)(a), underwriters must initiate Form G-32 on or before the date of first execution. The Late Initiation flag identifies compliance issues by comparing the Date of First Execution for an offering with the date the firm first initiated the offering’s Form G-32 within the MSRB’s Electronic Municipal Market Access (EMMA) system.
This flag requires a Date of First Execution to function. If, for some reason, the Date of First Execution was not provided on Form G-32, the flag would not identify the Form as being late but would result in an Unable to Process (UTP) flag. Users should use the Deal Summary to identify any Unable to Process entries with null entries in the First Trade Date column and investigate when necessary.
Any triggered Late Initiation flag indicates a compliance issue—either the firm initiated the form late or provided incorrect execution date/time information.
The information in this report card is provided to assist FINRA members in assessing and monitoring compliance with certain reporting obligations. All filing information contained in this report card has been provided by the MSRB and its accuracy has not been verified by FINRA. If inaccuracies are discovered or you have questions regarding the content of this specific report card, please send an email to the Report Center administrator at [email protected] or contact FINRA Regulatory Operations at (202) 728-8011.
Summary View
The Summary view of the MSRB G-32 Late Initiation Report Card provides a rolling 12 months of statistics related to submissions to EMMA required by MSRB Rule G-32. For more information on the requirements for submitting Form G-32, please review MSRB Rule G-32 and MSRB’s EMMA Primary Manual.
The table below provides a list of the fields, along with corresponding descriptions, found in the Summary view of the MSRB G-32 Late Initiation Report Card.
| Term | Description |
|---|---|
| Submission Totals | |
| Issuers by Period | This row analyzes forms submitted on behalf of issuers. |
| Firm | |
| Total Forms Count | The number of initial Form G-32 filings that were submitted to EMMA by the firm during the report card month. |
| Late Forms Count | The number of instances in which the firm, as underwriter, initiated Form G-32 one or more days after the Date of First Execution. When Form G-32 is initiated after the Date of First Execution, it is flagged as a “late filing” and included in the firm’s “Late Forms Count.” |
| Late Forms Percentage | Percentage of Form G-32 initiations that were flagged as late. |
| UTP Forms count | The number of instances in which Form G-32, for offerings underwritten by the firm, did not include a Date of First Execution and as a result, was flagged as Unable to Process (UTP). |
| UTP Forms Percentage | Percentage of Form G-32 initiations, by the firm, that were flagged as UTP. |
| Late Rank | For the all submitted filings section, the firm’s performance compared to all firms. For example, the firm with the worst late percentage would be ranked 1. |
| Industry | |
| Firm Count | The number of firms who initiated at least one initial Form G-32 to EMMA during the report card month. |
| Total Forms Count | The number of initial Form G-32 filings that were initiated by all firms during the report card month. |
| Late Forms Count | The total number of instances in which firms-initiated Form G-32 one or more days after the Date of First Execution. |
| Late Forms Percentage | The percentage of Late Forms Count to Total Form Count initiated in EMMA during the report card period by all firms. |
| UTP Forms count | The number of instances by all firms in which Form G-32 did not include a Date of First Execution and as a result, was flagged as UTP. |
| UTP Forms Percentage | Percentage of Form G-32 initiations by all firms that were flagged as UTP. |
| Term | Description |
|---|---|
| Lateness Magnitude | |
| Month | The month of the report card. |
| Firm | |
| 1 Day | The number of filings initiated one day late. |
| 2 Days | The number of filings initiated two days late. |
| 3-5 days | The number of filings initiated between three and five days late. |
| 6-15 days | The number of filings initiated between six and fifteen days late. |
| 16-30 days | The number of filings initiated between sixteen and thirty days late. |
| >31 days | The number of filings initiated thirty-one days late days late or more. |
| Average Lateness | The firm’s average lateness (by days) during the report card period. |
| Median Lateness | The firm’s median lateness (by days) during the report card period. |
| Industry | |
| Industry Average Lateness | The average lateness (by days) of all firm initiations of Form G-32 during the report card period. |
| Industry Median Lateness | The median lateness (by days) during the report card period. |
Details View
The Details view of the MSRB G-32 Late Initiation Report Card provides more information about the filings included in the Summary counts for a selected month. To generate the Details view, either click on the hyperlink for the desired month within the Summary tables or use the View dropdown at the top of the report card to navigate to the Details view.
The table below provides a list of the fields, along with corresponding descriptions, found in the Details view of the MSRB G-32 Late Initiation Report Card.
| Term | Description |
|---|---|
| Period | The month of the report card. |
| MSRB Number | This is the MSRB ID of the entity that submitted the filing to EMMA. If your firm has not designated an agent to submit to EMMA on your behalf, your firm's MSRB ID appears here. If a designated agent is submitting some or all of the firm’s filings, the agent’s MSRB ID is listed for the filings it submitted for your firm. |
| Underwriter Name | The name of the institution who underwrote the security. |
| CUSIP | This field contains the CUSIPs for the offering. The CUSIPs displayed depend on the type of offering, issue and security:
If the Offering Type is Bond and the Issue Type is Refunded, all of the Original CUSIP9s of the refunded securities are provided, as well as the CUSIP9 identifier of the refunding issue. These are not provided in any particular order, but the CUSIP9 identifier of the refunding issue can be identified by its absence of a final maturity date. |
| Submission Identifier | This is the unique identifier assigned by EMMA at the time of the first submission of data related to this offering. The same Submission Identifier should be used for all submission events (data submission, document submission, amendment submissions and/or cancellation) related to a single offering. |
| Closing Date | This is the date your firm indicates the issue is expected to settle. If this offering contains several issues and those issues have different closing dates, the report card displays the earliest closing date provided and uses that to calculate the closing time span (see below). |
| Submission Date | This is the date on which your firm submitted the document, notice of cancellation, or notice of exemption to EMMA. |
| Submission Time | This is the time at which your firm submitted the document, notice of cancellation, or notice of exemption to EMMA. |
| First Trade Date | The date on which the new issue of municipal securities first became available for trading in the market. |
| Days Late | The number of days between the date on which the underwriter initiated Form G-32 and the Date of First Execution. |
| Offering Type | This column indicates whether the filing is for a bond or municipal fund security offering. |
| Issue Type | This column indicates whether the filing is for a new issue or issues, an issue or issues being remarketed, or an issue or issues being refunded. This field is null for municipal fund submissions. |
| Security Type | This column indicates whether nine-digit CUSIP numbers are assigned to the securities in the issue(s) (CUSIP9), no CUSIP numbers are assigned to the securities in the issue(s) (non-CUSIP), or only a six-digit CUSIP has been submitted for the issue(s) (Commercial Paper). |
| Issuer | This is the name of the issuer of this offering. |
| Issue Description | This is the description of the issue(s) included in the offering. |
| EMMA Link | The address of the security’s details on EMMA. |