SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on an MSRB request for comment on a draft amendment to limit dealer consents to changes in authorizing documents for municipal securities.  SIFMA understands the MSRB’s investor protection concerns, and the difficulty in balancing those concerns with the need of issuers to update or modernize bond documents or make technical amendments to such documents.  SIFMA also recognizes the difficulty and expense in obtaining bondholder consents through existing processes, however does express concerns about the potential breadth of this draft amendment to MSRB Rule G-11.