SIFMA, BDA and NAMA on MSRB Proposed Changes to its Fee Setting Process

Published on:
July 6, 2022
Submitted to:
SEC
Submitted by:
SIFMA, BDA and NAMA
File Number:
SR-MSRB-2022-03

Summary

SIFMA, BDA and NAMA provided comments to the U.S. Securities and Exchange Commission (SEC) on the  Municipal Securities Rulemaking Board’s (MSRB) Proposed Changes to its Fee Setting Process.

Excerpt

July 6, 2022

Ms. Vanessa Countryman

Secretary, Securities and Exchange Commission

100 F Street, NE

Washington, DC. 20549

RE: File Number SR-MSRB-2022-03

Dear Ms. Countryman:

Our organizations represent broker-dealers and municipal advisors who are regulated by the Municipal Securities Rulemaking Board (MSRB). Our organizations appreciate the opportunity to comment on this filing.

While our organizations have differing opinions about some aspects of the Filing that will be expressed separately, we are taking this opportunity to discuss areas where we all agree – the need for the MSRB’s budget to be more transparent, and having MSRB resources used for tasks directly related to its statutory authority.

We are concerned that the MSRB’s efforts to adjust various fees to “adequately fund[ing] future MSRB expenses,” does not include review of the budget and linking of budgeted expenses to the MSRB’s congressional mandate. The members of our organizations have expressed ongoing concern that some of the MSRB’s funded initiatives are not germane to its statutory authority. We continue to request that the MSRB provide greater transparency regarding expenditures, especially with regard to expenses that do not support the important and necessary work the MSRB is authorized to execute.

The Filing does not detail what limits are in place to establish a basis or understanding of how overall expenditures are determined in a given year. Without such information, the MSRB is asking regulated entities to support a mechanism to pay fees needed to meet expenditures without information nor limits on those expenditures. This issue should be addressed so that our members can assess and the public can know what fees and other MSRB revenues are being used to fund activities outside of the MSRB’s statutory authority.

The questions about MSRB’s mission, expenditures and budget process are not new and have been highlighted in various letters from our organizations over the years. We are coming together today to highlight the important issues of the MSRB’s budget expenditures and mission, as these items are critical to the discussion of the revised MSRB fees structure.

Continue Reading

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.