SIFMA submits the first of two comment letters 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, MSRB Notice 2011-18.

SIFMA is taking the extraordinary step of submitting two comment letters regarding the Proposed Rule. This first letter contains significant input from municipal securities broker’s brokers (MSBBs) responsible for over 90% of the inter-dealer trading in municipal securities. The second letter, found here, contains significant input from a variety of broker-dealers (wire houses, mutual fund affiliates, and others) who regularly trade with MSBBs to meet their municipal securities trading needs.  Given the potential impact of the proposal, SIFMA asks that each of the letters be given careful consideration.

In this first letter, SIFMA questions whether any new MSRB rule directed solely at MSBBs is warranted, and requests that the MSRB withdraw the proposal, and continue to focus its resources on efficient coordination with the FINRA on the enforcement of existing MSRB rules.