SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed amendments to Municipal Securities Rulemaking Board (MSRB) G-17 Fair Dealing Interpretive Notice for Underwriters, SR-MSRB-2011-09.  While SIFMA strongly supports the MSRB’s efforts to provide guidance on the application of Rule G-17 to underwriters, SIFMA reiterates its concern over the timing of this proposal and urges the MSRB to take additional time to address certain flaws in the amended proposal.