If the MSRB pursues a pre-trade transparency initiative—though its necessity is debatable given the private sector has already addressed this need—it should leverage existing tools and services used by market participants.

The focus: municipal advisors — part of your regulatory responsibilities and duties (if you don't agree to evaluate pricing and/or structure, you must expressly disclose it to the client) and broker-dealers (fair dealing). 

While the MSRB's compliance resources are not a rule and it has not been filed with the SEC, one can infer that following the same will be beneficial should the SEC inquire.  

Technology enables us to be better, smarter, and faster and allows its adopters to focus on more substantive tasks, unearth insightful information and manage human relationships.  

The request for comments also asks whether the MSRB should amend the relevant rules or adopt/amend formal interpretive guidance that expressly defines a regulated entity's obligations with respect to new-issue pricing.

The settlement of a matter involving G-13 is the first time a firm has been charged with violating that rule since 2003 and left some wondering if FINRA was using enforcement cases to establish compliance standards.

One must be mindful of and pay close attention to obligor filings, credit spreads and, of course, rating actions whatever chair you sit in.

A painful reality of the current environment is that headcount is a target for cost reduction despite that demands have never been greater — compliance, client demands and the need to access and leverage data and information to avoid a competitive disadvantage.

It is feasible that not all COVID-19 filings are or will be material but one may want to err on the side of caution in this regard.

In the best of times, pricing municipal bonds is not so simple. In times of volatility, the challenge is magnified.