SIFMA provides comments to the U.S. Department of Treasury (Treasury) on regulatory guidance in development by Treasury and the Internal Revenue Service (IRS) of the definition of “issue price” in Treas. Reg. § 1.148-1(b).  Issuers and other marketplace participants continue to struggle with the resulting uncertainty surrounding the question of issue price in the-tax exempt market. This issue arose in 2009 and 2010 in the context of the Build America Bonds (BABs) program. SIFMA, along with the National Association of Bond Lawyers (NABL) and the Government Finance Officers Association (GFOA), previously submitted information to Treasury concerning the question of issue price for BABs. In this correspondence, SIFMA addresses in depth two areas of the underwriting and marketing process that should be considered by the Treasury and IRS in its deliberative process.