Revised SEC Rule 15c2-12

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the revised request for comment issued by the SEC on the existing collection of information provided for in Rule 15c2-12 – Municipal Securities Disclosure, under the Securities Exchange Act of 1934. We continue to be seriously concerned about the gross inaccuracies in the Current Notice and the Original Notice of the SEC’s time estimates for compliance with the Rule and the failure of the SEC to estimate the Rule’s primary disclosure compliance burdens, as separate and distinct from its secondary market compliance burdens.