SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on a proposal relating to gifts and gratuities rule for municipal advisors, MSRB Notice 2011-16.  The draft amendments would extend Rule G-20’s limitations on gifts and gratuities from brokers, dealers, and municipal securities dealers to gifts from “municipal advisors,” a category created by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  SIFMA generally supports the approach and goals of the MSRB proposal, and requests clarification that the proposed amendments do not exceed the reach of current Rule G-20. SIFMA recommends the MSRB expressly clarify that the proposed amendments to Rule G-20 simply extend the existing Rule G-20 framework, including related Financial Industry Regulatory Authority (FINRA) guidance, to municipal advisors.