NASD Regulation Inc. censured and fined 21 securities firms for violations of Municipal Securities Rulemaking Board Rule G-36, the Securities and Exchange Commission announced on Dec. 16, 2026. At the same time, the Comptroller of the Currency sanctioned Commerce Capital, a division of Commerce Bank, N.A., for similar violations, bringing the fines imposed in the coordinated proceedings to $325,000.

The proceedings resulted from a coordinated effort by the SEC, NASD Regulation and the OCC. The 21 securities firms received fines totaling $315,000, while Commerce Capital received a $10,000 fine from the OCC.

Sanctions by amount

  • $25,000 each: Bear, Stearns & Co. Inc.; Goldman, Sachs & Co.; J.P. Morgan Securities Inc.; PaineWebber Incorporated; Prudential Securities Incorporated; Smith Barney Inc.; and Sutro & Co. Inc.
  • $10,000 each: First of America Securities, Inc.; First Southwest Company; First Union Capital Markets Corp.; Merrill Lynch, Pierce, Fenner & Smith Inc.; Miller, Johnson & Kuehn, Inc.; Morgan, Keegan & Co., Inc.; Morgan Stanley & Co., Incorporated; Oppenheimer & Co., Inc.; Piper Jaffray Inc.; PNC Capital Markets, Inc.; Raymond James and Associates; Seattle-Northwest Securities Corp.; Stone & Young­

Rule G-36 requires firms underwriting municipal securities offerings to send the official statements from those offerings to the MSRB within one day of receiving the information from the issuer, and in no case later than 10 days from the date of the agreement to purchase the securities. The official statement is then placed in the MSRB’s Municipal Securities Information Library and made available to the public.

“Rule G-36 is an important investor protection rule.” — SEC Chairman Arthur Levitt

Levitt described the enforcement actions as a warning to municipal securities underwriters and said the lapses were widespread, involving national and regional securities firms as well as a bank. He said the rule’s requirements enhance disclosure quality and improve the integrity and efficiency of the municipal securities market, and emphasized that firms need procedures to comply with MSRB rules. Responsibility for enforcing those rules is shared by the SEC, NASD Regulation, the OCC, the Federal Reserve Board and the Federal Deposit Insurance Corporation.