SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on proposed amendments to Rule G-11 on new issue syndicate practices, Rule G-8 on books and records and Rule G-9 on preservation of records, Notice 2009-472. SIFMA believes that the solution proposed in the Notice is threefold; it would: 1) require that, unless otherwise agreed to by an issuer, the syndicate managers give priority to customer orders over orders for their own account, orders from an affiliate for its own account or orders for their respective related accounts; 2) expand the ambit of Rule G-11 to include all primary offerings (and not only syndicated transactions); and 3) add new definitions for the terms “affiliate” and “related account.”