The Bond Market Association (TBMA)* provides comments to the Securities and Exchange Commission (SEC) on securities offering reform and its impacts on the corporate debt markets, File No. S7-38-04. The proposal would modify the registration, communications and offering processes under the Securities Act of 1933.  TBMA believes the proposal represents a significant step toward achieving the goals of eliminating unnecessary restrictions on offerings, provide more timely investment information to investors and further integrate the disclosure process.  TBMA offers its observations and recommendations to enhance the proposal.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association in 2006.