Proposal Relating to the MSRB SHORT System

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposal relating to the Municipal Securities Rulemaking Board (MSRB) Short-term Obligation Rate Transparency (SHORT) System by changing MSRB Rule G-34, Release No. 34-58998; File No. SR-MSRB-2008-07.  SIFMA supports the collection and display of auction rate reset and remarketing rate reset information, but argues that January 30, 2009 is too soon to implement due to: 1) technology changes at firms can only begin to be planned when a final rule and specifications are approved; 2) broker dealers annually have two to four week “system freezes” scheduled in December and January for year-end system maintenance; 3) due to the scheduled year-end “system freezes”, many operations and technology staff schedule time off in December and January leaving the firms particularly shorthanded; and 4) this year has been a historic year for technological and operational issues due to the market dislocation and as a result there are many urgent technology and operations projects queued at broker dealer firms.