SIA Submits Comments to the MSRB Regarding the 529 Savings Plan Employees Payroll Deducion Programs
The Securities Industry Association (SIA)* provides comments to the Municipal Securities Rulemaking Board (MSRB) on a Draft Interpretive Notice on marketing of 529 Savings Plan Employees Payroll Deduction programs. SIA suggests the MSRB clarify that parties having obligations under such rules may satisfy such obligations through reasonable reliance on arrangements with other dealers, employers and/or issuers. SIA also suggests that a number of statements contained in the Notice are either unclear as to their application, or may lead to unintended consequences and should be clarified.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association in 2006.