SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on draft rule changes to establish an electronic access system for official statements, MSRB Notice 2007-33.  The notice proposes amendments to the original proposed amendments of MSRB Rule G-32 and Rule G-36.  SIFMA fully supports the development by the MSRB of a pilot portal as an internet-based public access portal, to provide free access to official statements and advance refunding documents, for a limited period of time in anticipation of a permanent system.  SIFMA encourages the Securities and Exchange Commission (SEC) to amend Rule 15c2-12 to provide for a centralized electronic submission and dissemination model. In addition, SIFMA requests that the MSRB design the permanent system to accommodate optional submission of preliminary official statements.