SIA Submits Comments to the SEC on a MSRB Proposal Relating to 529 College Savings Plans

The Securities Industry Association (SIA)* provides comments to the Securities Exchange Commission (SEC) on a proposalfor the Municipal Securities Rulemaking Board (MSRB)rule change relating to Marketing of 529 college savings plans in the workplace, Release NO. 34-47815; File No. SR-MSRB-2003-03.SIA believes that MSRB should re-assesswhether the 529 Plan accounts are actually “accounts” of either the selling broker or the primary distributor for purposes of the account/transaction approval requirements under Rule G-27 or the recordkeeping requirements Rule G-8. SIA suggests that the primary regulatory predicate for Rules G-8 and G-27 is to assure that all essential information has been obtained to evaluate the suitability of account transactions, and to create an audit trail to enable internal supervisory personnel and regulators to satisfy themselves that all suitabiltiy obligations have been met.

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