SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on a draft proposal to collect 529 college savings plan data, draft Rule G-45 and Form G-45, MSRB Notice 2012-40.  SIFMA shares their views on the proposal and urges the MSRB to be mindful of the cumulative costs involved to comply with any new reporting requirements and absent a compelling need for more frequent reporting, adopt a reporting schedule that is more in line with certain Securities and Exchange Commission (SEC) regulatory reporting for mutual funds.