SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on codifying time of trade disclosure obligation and Proposed Rule G-47, MSRB Notice 2013-04.  SIFMA generally supports the concept behind this initial effort by the MSRB to provide clarity to regulated entities by reorganizing or eliminating certain interpretive guidance associated with MSRB Rule G-17 into new or revised rules that highlight core principles.

However, SIFMA believes the Proposed Rule G-47 has significant gaps as well as represents a significant expansion of the existing time of trade obligation and does not fulfill the MSRB’s objective.