SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on the MSRB’s restated Sophisticated Municipal Market Professional (SMMP) notice, MSRB Notice 2011-63.  SIFMA supports the proposed revised definition of SMMP so that it is harmonized with Financial Industry Regulatory Authority’s (FINRA’s) revised suitability rule as it applies to institutional customers.  SIFMA recommends several ways in which the SMMP standard could be made even better. To the greatest extent possible, the SMMP standard should be harmonized with FINRA Rule 2111 as it applies to institutional customers. SIFMA feels that all institutional accounts under FINRA’s jurisdiction should be treated the same way.