Transparency of Municipal Auction Rate Securities and Variable Rate Demand Obligations

SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on transparency of municipal auction rate securities (ARS) and variable rate demand obligations, MSRB Notice 2009-43. The MSRB requests comment on its draft amendments to Rule G-34(c), on variable rate security market information, that would increase the amount of information currently collected and made transparent by the MSRB on municipal auction rate securities (ARS) and variable rate demand obligations (VRDOs). SIFMA is in favor of transparency generally, and specifically in favor of the transparency on the Electronic Municipal Market Access (EMMA) Dataport of many of the documents and data points set forth in the draft amendments. However, SIFMA feels strongly that broker dealers are not the appropriate parties to provide this information to EMMA as they are not a party to the requested documents, they are being asked to disclose information which may not be within their knowledge and the requirements will be extremely burdensome for them to fulfill.