Letters

Amendments to Rule G-10 Notification Requirement for Dealers

Summary

SIFMA submitted comments to the  Securities and Exchange Commission (“SEC”) on the Municipal Securities Rulemaking Board’s (“MSRB’s”) Filing of a Proposed Rule Change Consisting of Amendments to Rule G–10, on Investor and Municipal Advisory Client Education and Protection, and Rule G–48, on Transactions With Sophisticated Municipal Market Professionals, To Amend Certain Dealer Obligations (the “Filing”).

SIFMA supports many elements of the proposed amendments, which reduce the compliance burden on the dealer community without reducing investor protections. The proposed amendments will render potential cost savings, and each customer notification that no longer needs to be printed or mailed will reduce the environmental impact of this process.

PDF

Submitted To

SEC

Submitted By

SIFMA

Date

10

September

2021

Excerpt

September 10, 2021

VIA ELECTRONIC SUBMISSION

Vanessa A. Countryman
Secretary
Securities and Exchange
Commission, 100 F Street, NE
Washington, DC 20549

Re: File Number SR–MSRB–2021–04; MSRB Notice 2021-08 – Amendments to Rule G-10 Notification Requirement for Dealers__

Dear Ms. Countryman,

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates this opportunity to provide input to the Securities and Exchange Commission (“SEC”) on the Municipal Securities Rulemaking Board’s (“MSRB’s”) Filing of a Proposed Rule Change Consisting of Amendments to Rule G–10, on Investor and Municipal Advisory Client Education and Protection, and Rule G–48, on Transactions With Sophisticated Municipal Market Professionals, To Amend Certain Dealer Obligations (the “Filing”).2 SIFMA appreciates the MSRB review of Rule G-10, as part of its retrospective rule review. SIFMA supports many elements of the proposed amendments, which reduce the compliance burden on the dealer community without reducing investor protections. The proposed amendments will render potential cost savings, and each customer notification that no longer needs to be printed or mailed will reduce the environmental impact of this process. The ongoing COVID-19 pandemic also adds an additional risk for dealer staff that need to produce and mail these physical customer notifications. In that vein, the recent societal changes mean that many recipients of these
notifications may not be receiving mail at their offices and may be less willing to touch any mail they do receive.

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S.regional member of the Global Financial Markets Association (GFMA).
2 86 Fed. Reg. 46890 (Aug. 20, 2021).