SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) in response to the Request for Comment on Proposed Rule Amendments and Interpretive Notice on Retail Order Periods.

SIFMA believes the concerns raised in MSRB Notice 2012-13 could be addressed through the enforcement of existing principles based rules, or a clarifying regulatory notice, though we support the proposed rule changes to the extent they would protect dealers that follow issuers’ instructions, clarify issuer terms and conditions, and require timely notice of retail order period terms and conditions to all syndicate and selling group members. SIFMA made recommendations on how best to address the issue.