SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on the MSRB’s Concept Release on pre-trade and post-trade pricing data dissemination through a new central transparency platform (MSRB Notice 2013-14), in which the MSRB is requesting comment on the specific data elements the MSRB is considering disseminating publicly through a new central transparency platform (CTP) with respect to both pre-trade and post-trade pricing information.

SIFMA continues to have some specific concerns about these proposals. We believe that some of these proposals will be misleading to investors, potentially harm liquidity and the health of the secondary market for municipal securities, and drive up transaction costs in the industry. We feel the benefits of these proposals do not measure up to the astronomical costs and burdens they will impose upon the broker dealers who will be required to send this information to the MSRB. Each significant change in transparency is driven by a change in reporting which not only costs the reporting dealer time and money to change their systems but also to add personnel to undertake the new reporting, surveillance, and supervision.