SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on revised draft rule amendments and revised draft interpretive notice on retail order periods, MSRB 2012-50, which proposes amendments to MSRB Rules G-11 (on primary offering practices), G-8 (on books and records), and G-32 (on disclosures in connection with primary offerings), as well as an interpretive notice concerning the application of MSRB Rules G-17 and G-30 to retail order periods.  While SIFMA believes that the concerns raised in Notices 2012-13 and 2012-50 have now been addressed through a clarifying regulatory notice, which should ease the enforcement of existing MSRB rules and fair dealing obligations, SIFMA supports 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.