Self-Regulatory Organizations; Municipal Securities Rulemaking Board; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change Consisting of Interpretive Guidance About Frequently Asked Questions Regarding the Use of Social Media Under the MSRB's Advertising Rules

Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 (the “Act”) and Rule 19b-4 thereunder, notice is hereby given that on February 26, 2019 the Municipal Securities Rulemaking Board (“MSRB”) filed with the Securities and Exchange Commission (“SEC” or “Commission”) the proposed rule change as described in Items I, II, and III below, which Items have been prepared by the MSRB. The Commission is publishing this notice to solicit comments on the proposed rule change from interested persons.

I. Self-Regulatory Organization's Statement of the Terms of Substance of the Proposed Rule Change

The MSRB filed with the Commission a proposed rule change consisting of interpretive guidance about frequently asked questions regarding the use of social media under MSRB Rule G-21, on advertising by brokers, dealers and municipal securities dealers, and MSRB Rule G-40, on advertising by municipal advisors (Rule G-21, together with Rule G-40, the “advertising rules”). The proposed rule change has been filed for immediate effectiveness under Section 19(b)(3)(A) of the Exchange Act and Rule 19b-4(f)(6) thereunder. The effective date of the amendments to Rule G-21 and Rule G-40 will be announced in an MSRB Notice to be published on the MSRB's website following the effectiveness of this proposed rule change. To provide brokers, dealers, municipal securities dealers and municipal advisors (collectively, “regulated entities”) with sufficient time to develop supervisory and compliance policies and procedures, the effective date to be announced will be no less than 30 days and no more than 180 days following publication of the MSRB Notice.

The text of the proposed rule change is available on the MSRB's website at www.msrb.org/Rules-and-Interpretations/SEC-Filings/2019-Filings.aspx,, at the MSRB's principal office, and at the Commission's Public Reference Room.

II. Self-Regulatory Organization's Statement of the Purpose of, and Statutory Basis for, the Proposed Rule Change

In its filing with the Commission, the MSRB included statements concerning the purpose of and basis for the proposed rule change and discussed any comments it received on the proposed rule change. The text of these statements may be examined at the places specified in Item IV below. The MSRB has prepared summaries, set forth in Sections A, B, and C below, of the most significant aspects of such statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and Statutory Basis for, the Proposed Rule Change

1. Purpose

The purpose of the proposed rule change is to clarify for brokers, dealers, and municipal securities dealers (collectively, “dealers”) and municipal advisors the application of the recent amendments to Rule G-21 and new Rule G-40 to the use of social media by regulated entities in connection with their municipal securities activities and municipal advisory activities. The MSRB committed to providing that guidance before the effective date of the amendments to the advertising rules, and developed draft guidance regarding the use of social media in the format of frequently asked questions (the “FAQs”).

While developing the proposed rule change, the MSRB was mindful of the potential burden on a regulated entity if there were to be unnecessary inconsistencies between any adopted MSRB social media guidance and similar guidance issued by other regulators that may be applicable to other aspects of the regulated entity's business. To inform its approach, the MSRB consulted with staff from the Financial Industry Regulatory Authority, Inc. (“FINRA”). The MSRB endeavored, to the extent practicable, to align the FAQs with the social media guidance published by the SEC and FINRA.

The FAQs are divided into four categories: Use of social media, third-party posts, recordkeeping and supervision. Further, the FAQs would provide references to additional resources that may be of use to the regulated entity.

Use of Social Media. The FAQs would provide guidance about when a regulated entity's or its associated person's use of social media becomes an “advertisement” under the advertising rules. The FAQs would clarify that, depending on the facts and circumstances and with limited exceptions, any material (including material that is posted on an associated person's personal social media) that relates to (i) the products or services of the dealer, (ii) the services of the municipal advisor, or (iii) the engagement of a municipal advisory client by the municipal advisor, may constitute an advertisement under the MSRB's advertising rules, if it is published or used in any electronic or other public media or written or electronic promotional literature distributed or made generally available to either customers or municipal entities, obligated persons, municipal advisory clients or the public.

Further, the FAQs would address:

• The other MSRB rules to consider when a regulated entity uses social media as part of its municipal securities or municipal advisory activities;
• the requirement for principal pre-approval of an advertisement; and
• a regulated entity's website hyperlinking to content on an independent third-party's website.

In particular, the FAQs would highlight the other obligations under MSRB rules that regulated entities may have, in addition to those set forth in the advertising rules, regarding the use of social media. Those other regulatory obligations would include obligations under: Rule G-17, on conduct of municipal securities and municipal advisory activities; Rule G-27, on supervision; Rule G-44, on supervisory and compliance obligations of municipal advisors; Rule G-8, on books and records to be made by brokers, dealers, municipal securities dealers, and municipal advisors; and MSRB Rule G-9, on retention of records.

Further, the FAQs would reinforce that a social media post that contains an advertisement, as defined under the advertising rules, would be subject to approval by a principal prior to its first use.

The FAQs would provide guidance regarding hyperlinking to an independent third-party website from a regulated entity's website. The FAQs would discuss the concepts of entanglement—i.e., whether the regulated entity involved itself in the preparation of the content on the third-party website—and adoption—i.e., whether the regulated entity implicitly or explicitly approved or endorsed the content on that third-party website. The FAQs then would state that the advertising rules would apply to hyperlinked content on an independent third-party's website if the regulated entity either were to become entangled with or adopt that content.

To assist regulated entities, the FAQs would identify various factors that would be relevant in determining whether a regulated entity has adopted or become entangled with the independent third-party hyperlinked content. Those factors would include: The context of the hyperlinked content; the potential for customer or municipal advisory client confusion about the source of the content; and the nature of the hyperlinked content (i.e., hosted by an independent third-party that is not controlled or influenced by the regulated entity with an “ongoing” link). Further, the FAQs would provide that the inclusion by a regulated entity of a disclaimer would not, alone, be sufficient to avoid potential MSRB rule violations for hyperlinked content on an independent third-party website if the regulated entity knows, or has reason to know, that such content is materially false or misleading. However, the FAQs would highlight that MSRB rules would not apply to linked content within the independent hyperlinked content to which the regulated entity had hyperlinked.

Third-party posts. The FAQs would provide guidance regarding when a post by a customer, a municipal entity client or another third-party (collectively, a “third-party post”) on a regulated entity's social media page may be considered advertising under the advertising rules. Further, the FAQs would provide that if the regulated entity were to become entangled with or adopt such third-party posts, such third-party posts would become subject to the advertising rules.

In addition, the FAQs would provide guidance regarding whether a municipal advisory client may post positive comments on a municipal advisor's social media page about the municipal advisor's municipal advisory activities without that post being deemed an advertisement containing a testimonial under Rule G-40. That guidance would provide that such post on the municipal advisor's social media page would only be deemed to be an advertisement containing a testimonial under Rule G-40 if the municipal advisor were to either be entangled with or adopt the post.

Recordkeeping. The FAQs would clarify that “posts,” “chats,” text messages, or messages sent through messaging applications related to a regulated entity's municipal securities or municipal advisory activities conducted through social media—regardless of (i) whether the social media is specifically identified as business or personal, (ii) the technology used for the messaging, or (iii) the device used for the messaging was issued by the regulated entity— are subject to the MSRB's recordkeeping rules (i.e., Rules G-8 and G-9).

Specifically, for dealers, Rule G-9(b)(viii)(C) requires that “all written and electronic communications received and sent, including inter-office memoranda, relating to the conduct of the activities of such municipal securities broker or municipal securities dealer with respect to municipal securities” be retained. Similarly, for municipal advisors, Rule G-9(h)(i) requires the retention of records, which include, among other things, originals or copies of all written and electronic communications received and sent, including inter-office memoranda, relating to municipal advisory activities. Neither the technology used for the communication nor the distinction between a communication made through a devise issued by a regulated entity or its associated person's personal device is determinative for this requirement.

Supervision. The FAQs would list MSRB rules, including the advertising rules, Rule G-17, Rule G-8 and Rule G-9, as well as other factors, such as usage restrictions, training and education, recordkeeping and monitoring, that are relevant to the development of policies and procedures regarding social media use. The FAQs also would provide guidance under Rule G-27 and Rule G-44 about factors that may be important for a regulated entity to consider in determining the effectiveness of its policies and procedures regarding social media.

Additional materials. The FAQs also would refer to resources where additional information about the MSRB's advertising rules could be obtained. Those resources would include the materials submitted to the Commission in File No. SR-MSRB-2018-01 related to the recent amendments to Rule G-21 and new Rule G-40, MSRB Notice 2018-08 concerning the SEC's approval of those recent amendments to Rule G-21 and new Rule G-40 and MSRB Notice 2018-32 concerning the application of the content standards to advertisements by municipal advisors under Rule G-40.

2. Statutory Basis

Section 15B(b)(2) of the Exchange Act provides that:

[t]he Board shall propose and adopt rules to effect the purposes of this title with respect to transactions in municipal securities effected by brokers, dealers, and municipal securities dealers and advice provided to or on behalf of municipal entities or obligated persons by brokers, dealers, municipal securities dealers, and municipal advisors with respect to municipal financial products, the issuance of municipal securities, and solicitations of municipal entities or obligated persons undertaken by brokers, dealers, municipal securities dealers, and municipal advisors.

Section 15B(b)(2)(C) of the Exchange Act provides that the MSRB's rules shall:

be designed to prevent fraudulent and manipulative acts and practices, to promote just and equitable principles of trade, to foster cooperation and coordination with persons engaged in regulating, clearing, settling, processing information with respect to, and facilitating transactions in municipal securities and municipal financial products, to remove impediments to and perfect the mechanism of a free and open market in municipal securities and municipal financial products, and, in general, to protect investors, municipal entities, obligated persons, and the public interest.

The MSRB believes that the proposed rule change is consistent with Sections 15B(b)(2) and 15B(b)(2)(C) of the Exchange Act. The proposed rule change would help to prevent fraudulent and manipulative practices; foster coordination with persons engaged in regulating transactions in municipal securities; and protect investors, municipal entities, obligated persons, and the public interest.

The MSRB believes that the proposed rule change is designed to prevent fraudulent and manipulative practices. The proposed rule change would provide guidance to a regulated entity regarding the use of social media under the advertising rules. By providing this guidance, the MSRB makes clear that certain social media use by a regulated entity would be advertising, and as such, that social media use must comply with the standards of the advertising rules, including the content standards. Those standards provide, among other requirements, that advertisements be based on the principles of fair dealing and good faith, be fair and balanced, and provide a sound basis for evaluating the facts and that the advertisements not make any false, exaggerated, unwarranted, promissory or misleading statement or claim.

Because the MSRB has endeavored to make its advertising rules, including its social media guidance, consistent with the communications rules and social media guidance published by other financial regulators, to the extent practicable, a regulated entity that is dually registered as a broker, dealer or investment adviser with the SEC may be able to more easily understand and develop consistent practices across business lines, and therefore promote compliance with the MSRB's advertising rules. In turn, this improved compliance would help prevent fraudulent and manipulative practices because the proposed rule change is designed to assist with and promote compliance with the advertising rules, rules that in and of themselves are designed to prevent fraudulent and manipulative practices.

In addition, the proposed rule change would foster coordination with persons engaged in regulating transactions in municipal securities. As noted under “Self-Regulatory Organization's Statement of the Purpose of, and Statutory Basis for, the Proposed Rule Change,” regulatory coordination has already occurred with respect to the proposed rule change as the MSRB has consulted with FINRA staff to inform its approach to the FAQs. Further, by providing social media guidance that would be consistent with the social media guidance of other financial regulators (including the social media guidance published by the SEC and FINRA, regulators that are charged with inspecting for compliance with MSRB rules), to the extent practicable, those other financial regulators would be familiar with the social media guidance, which in turn, should foster efficient examinations by those other financial regulators of MSRB-regulated entities. In addition, a regulated entity that is dually registered with the MSRB and with FINRA would be treated the same under the advertising rules as a regulated entity that is registered with the MSRB and not with FINRA. Thus, because the MSRB has endeavored to make the proposed rule change consistent with the communications rules and social media guidance of FINRA, the proposed rule change would help ensure that all regulated entities are subject to consistent advertising regulation.

The proposed rule change also would help protect investors and the public interest. The MSRB believes that the clear guidance provided by the proposed rule change would help to ensure that social media use by a regulated entity that constitutes advertising complies in a consistent way with the advertising rules as well as relevant supervision and recordkeeping rules.

B. Self-Regulatory Organization's Statement on Burden on Competition

Section 15B(b)(2)(C) of the Exchange Act requires that MSRB rules not be designed to impose any burden on competition not necessary or appropriate in furtherance of the purposes of the Exchange Act.

The MSRB's policy on the use of economic analysis does not apply to rulemaking proposals for which the MSRB seeks immediate effectiveness. However, even though the MSRB did not conduct a full economic analysis of the proposed rule change, the MSRB still conducted an internal analysis to gauge the economic impact of the proposed rule change, with an emphasis on the burden on competition involving regulated entities.

In this regard, the MSRB believes the proposed rule change is necessary and appropriate in the furtherance of the purposes of the Exchange Act because it would promote compliance by regulated entities by promoting clarity regarding the intended application of the MSRB's rules and would reduce confusion concerning the application of its rules. The MSRB also believes the proposed rule change would promote regulatory consistency with the social media guidance published by the SEC and FINRA. In addition, the proposed rule change would apply the social media guidance uniformly to dealers and municipal advisors, to the extent practicable, which promotes consistency and preserves competitive balance between regulated entities with different business models.

Effect on Competition, Efficiency and Capital Formation

The MSRB does not believe that the proposed rule change would result in any burden on competition that is not necessary or appropriate in furtherance of the purposes of the Exchange Act, as the proposed rule change is applicable to all dealers and municipal advisory firms.

Section 15B(b)(2)(L)(iv) of the Exchange Act provides that MSRB rules may “not impose a regulatory burden on small municipal advisors that is not necessary or appropriate in the public interest and for the protection of investors, municipal entities, and obligated persons, provided that there is robust protection of investors against fraud.” The MSRB believes that, although the proposed rule change would affect all municipal advisors, including small municipal advisors, the proposed rule change is meant to clarify existing MSRB rules and therefore would not impose additional burdens on municipal advisors regardless of firm size.

C. Self-Regulatory Organization's Statement on Comments on the Proposed Rule Change Received From Members, Participants, or Others

The MSRB sought public comment on the FAQs in draft form. In response to that request for comment, the MSRB received four comment letters. Commenters generally expressed support for the guidance contained in the FAQs, but also expressed various concerns and suggested certain revisions. In particular, commenters focused on three areas—interactive versus static communications, interpretations of FINRA's social media guidance, and additional guidance. Below, the MSRB discusses the comments received.

Interactive Versus Static Communications

Commenters requested that the MSRB adopt the concepts of interactive and static content posted or disseminated to social media sites as described in FINRA Regulatory Notice 10-06. In that notice, FINRA provides examples of both interactive and static content, and provides guidance that the definition of public appearance under FINRA Rule 2210(f) includes unscripted participation in an interactive electronic forum. Since RN 10-06, however, FINRA has amended FINRA Rule 2210 so that such communications are now defined as retail communications that are excepted from the requirement of principal pre-approval. Nevertheless, such retail communications in interactive forums are subject to other supervisory requirements and are subject to content standards of FINRA's communications rule. However, FINRA considers static content to constitute “advertisements” under FINRA Rule 2210 and requires principal approval of such content prior to posting.

In response, the MSRB has determined to propose to amend its advertising rules to address commenters' suggestions. Concurrent with this proposed rule change, the MSRB has submitted a separate proposed rule change with the Commission to do so.

Interpretations of FINRA's Social Media Guidance

Commenters requested that the MSRB adopt their interpretations of certain aspects of FINRA's social media guidance. Specifically, commenters requested that the MSRB adopt interpretations regarding the adoption of third-party content, hyperlinks, and FINRA's social media guidance.

Adoption. SIFMA commented that “SIFMA and its members “don't view `liking' as the adoption of content” and explained that current FINRA guidance defines adoption “in regard to sharing or linking” but not `liking'.” Similarly, Wells Fargo suggested that the FAQs would not align with FINRA's guidance in FINRA Regulatory Notice 17-18 regarding adoption because simply “liking” a post does not rise to the level of “sharing” or “linking.”

FINRA has provided guidance that it would deem adoption as explicitly or implicitly endorsing or approving third-party content, and that by liking or sharing unsolicited favorable third-party content posted on a representative's business-use social media website, the representative would be adopting that content. In addition, the MSRB submits that FINRA's guidance relating to “shares” and “links” to which commenters refer, by its own terms, does not provide the exclusive list of how a firm can adopt independent third-party content, but rather responds to a narrow question regarding sharing and linking. Consistent with the SEC's and FINRA's social media guidance, the FAQs would provide that a regulated entity may adopt the content of a third-party post if the regulated entity explicitly or implicitly approves or endorses the content. Further, based on that guidance, the FAQs would provide that, if a regulated entity “likes” or otherwise indicates approval with that third-party post, then the regulated entity has adopted that third-party post. The FAQs would provide non-exclusive factors for a regulated entity to consider when determining whether the regulated entity has adopted third-party content.

The MSRB believes that the FAQs would correctly interpret the theory of adoption as it applies to “likes” of third-party content and would promote regulatory consistency with the interpretations of other financial regulations. The MSRB has determined not to modify the FAQs in response to SIFMA's and Wells Fargo's suggestions for “liking” a post as doing so would create disharmony among the applicable regulatory interpretations.

Relatedly, NAMA provided three suggestions regarding adoption and entanglement. NAMA suggested that the FAQs' guidance regarding the entanglement or adoption by a municipal advisor of third-party content was inconsistent with the MSRB's guidance in MSRB Notice 2018-24 regarding testimonials. In particular, NAMA expressed concern that by simply allowing third-parties to post on a municipal advisor's social networking page, and specifically, by allowing a municipal advisory client to post positive comments on a municipal advisor's social networking page, the municipal advisor, itself, would be allowing an advertisement that was a testimonial to be posted. As provided in question 8, a municipal advisor would only be posting an advertisement that contains a prohibited testimonial under Rule G-40 if the municipal advisor were to become entangled with or adopt the positive comments of the municipal advisory client. To provide clarity, the MSRB has revised question 8 so that it now asks “May a municipal advisory client post positive comments about its experience with the municipal advisor on the municipal advisor's social media page without such post being deemed a testimonial within Rule G-40?”

Further, NAMA suggested that the use of the term “encourage” when defining entanglement was inconsistent with SEC and FINRA language regarding entanglement. To be responsive to NAMA's concerns, the MSRB has deleted references to “encourage” when discussing entanglement.

NAMA also suggested that the MSRB explicitly define the terms “customer complaint” and “municipal advisory client complaint” when discussing third-party posts on an associated person's social networking page. After considering NAMA's suggestion, the FAQs provide a reference to the definition of those terms in Rule G-8.

Hyperlinks. SIFMA and Wells Fargo recommended that the MSRB align its guidance in question 4 relating to ongoing links with the guidance provided by FINRA in question 5 in RN 17-18. In particular, those commenters suggested that FINRA has provided guidance that the determination of whether an ongoing hyperlink contains misleading information is only made at the time the firm determines to offer a particular hyperlink. SIFMA and Wells Fargo note that a firm would not have the capacity to monitor the third-party website on a continual basis.

Question 4 would provide guidance about ongoing links that would promote regulatory consistency with FINRA's guidance in question 5 of RN 17-18. In particular, the FAQs would define an ongoing link, consistent with FINRA's definition of an ongoing link, and provide guidance that hyperlinked content may not be advertising subject to the advertising rules if the hyperlink containing the independent third-party content is ongoing and the regulated entity has no influence or control over the independent third-party hosting the content. The FAQs then would provide guidance about the factors that a regulated entity may want to consider if the hyperlinked content is advertising subject to the advertising rules. Similar to FINRA's guidance in RN 17-18, question 4 in MSRB's FAQs would not specifically address requirements to monitor an ongoing link under the MSRB's advertising rules. Because the MSRB believes that the FAQs' guidance regarding ongoing hyperlinks would promote regulatory consistency with the relevant guidance of other financial regulators, the MSRB has determined not to expand the guidance regarding ongoing hyperlinks to address commenters' suggestions.

Adoption of FINRA social media guidance. SIFMA suggested that, because FINRA has a long history of rulemaking and guidance with respect to social media issues, it would be helpful if dealers could rely on FINRA's social media or other guidance.” The MSRB appreciates SIFMA's suggestion, and in developing the FAQs, the MSRB was mindful of the potential burden on a regulated entity if there were to be unnecessary inconsistencies between any adopted MSRB social media guidance and similar guidance issued by other regulators that may be applicable to other aspects of the regulated entity's business. To that end, and to the extent practicable, the MSRB endeavored to align the FAQs with the social media guidance published by the SEC and FINRA.

The MSRB is aware that the use of social media is an evolving landscape, and recognizes that the MSRB will likely need to continue to issue guidance in this area as practices and technology evolve and as other regulators issue new rules and official guidance regarding social media. The MSRB will continue to monitor developments in this area (including rules and guidance of other regulators and enforcement matters) and to seek input from regulated entities regarding the need to issue additional guidance. In so doing, the MSRB will continue to be mindful of the importance of regulatory certainty for regulated entities as well as avoiding unnecessary discrepancies between the obligations of dealers and municipal advisors, including between municipal advisors that are also registered as dealers and municipal advisors that are not registered as dealers (that may include municipal advisors that are banks).

Related to SIFMA's suggestion about adopting FINRA's social media guidance, are NAMA's questions regarding the MSRB's use of footnotes to reference FINRA's social media guidance and the SEC's social media guidance in the FAQs. Specifically, NAMA questions what the footnotes mean. The MSRB endeavors to promote regulatory consistency with other financial regulators, when appropriate. The MSRB provided certain references to where the MSRB is promoting regulatory consistency with the social media guidance of other regulators. Those footnotes, however, are not intended to suggest that regulated entities that are not already subject to the guidance issued by the SEC and FINRA are now obligated to act consistent with the MSRB's social media guidance as well as with the social guidance published by the SEC or FINRA.

Additional Guidance

The request for comment solicited suggestions where additional guidance regarding social media use would be helpful. Commenters provided suggestions specifically relating to the social media guidance provided by the FAQs as discussed above, as well as to other relevant topics. NAMA suggested that the MSRB provide additional social media guidance specifically relating to disclaimers and hyperlinks. In addition, NAMA suggested that the MSRB provide municipal advisors guidance on the supervisory obligations related to the use of electronic communications technology by a firm's associated persons similar to FINRA's guidance in FINRA Regulatory Notice 07-59. NAMA noted that such guidance could be particularly helpful to small municipal advisors in assessing the compliance costs associated with social media usage. SIFMA also provided suggestions. Specifically, SIFMA provided a list of other issues that would benefit from further clarification that included, among other issues, the definition of advertising and exemptions thereof, and documentation standards.

Any comments that may not have been specifically addressed in the FAQs provide valuable input to inform the MSRB as it considers developing additional guidance.

III. Date of Effectiveness of the Proposed Rule Change and Timing for Commission Action

Because the foregoing proposed rule change does not: (i) Significantly affect the protection of investors or the public interest; (ii) impose any significant burden on competition; and (iii) become operative for 30 days from the date on which it was filed, or such shorter time as the Commission may designate, it has become effective pursuant to Section 19(b)(3)(A) of the Act and Rule 19b-4(f)(6) thereunder.

At any time within 60 days of the filing of the proposed rule change, the Commission summarily may temporarily suspend such rule change if it appears to the Commission that such action is necessary or appropriate in the public interest, for the protection of investors, or otherwise in furtherance of the purposes of the Act.

IV. Solicitation of Comments

Interested persons are invited to submit written data, views, and arguments concerning the foregoing, including whether the proposed rule change is consistent with the Act. Comments may be submitted by any of the following methods:

Electronic Comments

• Use the Commission's internet comment form ( http://www.sec.gov/rules/sro.shtml ); or
• Send an email to rule-comments@sec.gov. Please include File Number SR-MSRB-2019-04 on the subject line.

Paper Comments

• Send paper comments in triplicate to Secretary, Securities and Exchange Commission, 100 F Street NE, Washington, DC 20549.

All submissions should refer to File Number SR-MSRB-2019-04. This file number should be included on the subject line if email is used. To help the Commission process and review your comments more efficiently, please use only one method. The Commission will post all comments on the Commission's internet website ( http://www.sec.gov/rules/sro.shtml ). Copies of the submission, all subsequent amendments, all written statements with respect to the proposed rule change that are filed with the Commission, and all written communications relating to the proposed rule change between the Commission and any person, other than those that may be withheld from the public in accordance with the provisions of 5 U.S.C. 552, will be available for website viewing and printing in the Commission's Public Reference Room, 100 F Street NE, Washington, DC 20549 on official business days between the hours of 10:00 a.m. and 3:00 p.m. Copies of the filing also will be available for inspection and copying at the principal office of the MSRB. All comments received will be posted without change. Persons submitting comments are cautioned that we do not redact or edit personal identifying information from comment submissions. You should submit only information that you wish to make available publicly. All submissions should refer to File Number SR-MSRB-2019-04 and should be submitted on or before March 27, 2019.