Primary Market Disclosure and Primary Market Subscription Services

SIFMA provides comments to the Securities and Exchange Commission (SEC) regarding a notice of filing with the SEC of a proposed rule change by the Municipal Securities Rulemaking Board (MSRB) relating to Rule G-32, and the primary market disclosure and primary market subscription services of the MSRB’s Electronic Municipal Market Access system (EMMA), File No. SR-MSRB-2009-09. The proposed rule change would require brokers, dealers and municipal securities dealers (collectively, dealers), acting as underwriters, placement agents or remarketing agents for primary offerings of municipal securities, to provide to EMMA information about whether the issuer or other obligated person has undertaken to provide continuing disclosure, the identity of any obligated persons other than the issuer and the timing by which such issuers or obligated persons have agreed to provide annual financial and operating data. SIFMA believes that the proposed amendments do not promote those goals and, consequently, are not in the best interest of investors.