SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on the MSRB’s initiative to review its rules and interpretive guidance, MSRB Notice 2012-63.  SIFMA and its members commend the MSRB for pro-actively soliciting comments to determine whether any rules or guidance should be revised or restated due to changes in market practices or conditions, or to be more closely aligned with rules of other self-regulatory organizations or government agencies so as to promote more effective and efficient compliance. SIFMA’s comments are divided into two areas: first, guiding themes which our members believe should direct MSRB rulemaking; and secondly, specific suggestions to revise specific rules due to changed market practices, or promote greater compliance efficiencies.