Ronald W. Smith
Municipal Securities Rulemaking Board
1300 I Street NW Suite 1000
Washington, DC 20005
Re: MSRB Notice 2019-01: Request for Comment on Draft Interpretive Guidance on Application of MSRB Rules to Certain Prearranged Trading in Connection with Primary Offerings
Dear Mr. Smith:
The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates this opportunity to respond to Notice 2019-01 (the “Notice”)2 issued by the Municipal Securities Rulemaking Board (the “MSRB”) in which the MSRB is requesting comment on draft interpretive guidance on application of MSRB rules and prior interpretive guidance to certain prearranged trading in connection with primary offerings of municipal securities.
I. MSRB Should Defer Action on the Notice
In light of ongoing Securities and Exchange Commission (“SEC”) examination and enforcement activity with respect to these issues, some SIFMA members are not in a position to participate in the comment process on this subject at this time. Therefore, we respectfully, yet strongly, request the MSRB withdraw the request for comment or otherwise defer proceeding on any related guidance or rulemaking until the SEC concludes its enforcement activity in this area.
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