MSRB Rules G-8, G-9, G-18, and Draft Rule G-43

SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on MSRB Draft Rule G-43 and associated amendments to Rules G-8, G-9, and G-18, and draft interpretive notice on the obligations of dealers that use the services of broker’s brokers, MSRB Notice 2011-50.  SIFMA supports effective and efficient regulation of the municipal securities markets that helps to aid market liquidity in a manner consistent with customer protection.  While SIFMA acknowledges the progress of the proposed rule since the initial proposal, it believes that there are certain aspects of the proposed rule that the MSRB should consider revising, in order to ensure that the final rule adopted will be as useful and effective as possible.