SIFMA provides comments to the Municipal Securities Rulemkaing Board (MSRB) on a revised draft rule requiring underwriters to submit 529 college savings plan information to the MSRB, MSRB Notice 2012-59.  SIFMA applauds the revisions to the proposal including: reducing the reporting frequency from quarterly to semiannually; providing filers a 60-day lag time to report the semi-annual information; providing filers an implementation period of at least one year following approval by the Securities and Exchange Commission (SEC); and revising certain terms and definitions. However, SIFMA continues to have concerns with aspects of the proposal, which SIFMA believes requires further clarification from the MSRB.