SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed rule change consisting of proposed MSRB Rule G-47, on time of trade disclosure obligations, proposed revisions to MSRB Rule G-19, on suitability of recommendations and transactions, proposed MSRB Rules D-15 and G-48, on sophisticated municipal market professionals, and the proposed deletion of interpretive guidance, Release No. 34–70593; SR-MSRB-2013-07.

SIFMA continues to support the efforts 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.

As the multiple rule proposals are interrelated, SIFMA also supports the packaging of these multiple rules changes into a single filing with the SEC. Additionally, SIFMA supports the MSRB efforts to harmonize MSRB Rule G-19 with FINRA Rule 2111 – as current Rule G-19 had been harmonized with the predecessor rule to FINRA 2111, NASD 2310. However, SIFMA’s members believe that additional adjustments are warranted to these proposed rules and rule amendments to fully capture the current regulatory requirements. Further, additional time to implement certain rule changes is warranted.