SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on the MSRB’s Concept Proposal to require underwriters to submit preliminary official statements (POSs) to the MSRB’s Electronic Municipal Market Access (EMMA) System, MSRB Notice 2012-61.  SIFMA has concerns about the Proposal that should be addressed by the MSRB prior to proceeding to rule making (if rulemaking is ultimately deemed necessary). Additionally, SIFMA suggests that the fastest way to make POSs available to retail investors is through educational outreach to municipal issuers, hopefully resulting in a new market best practice of posting the POS voluntarily on EMMA. SIFMA urges the MSRB to carefully weigh the incremental benefits to a small pool of retail investors that would actually review a POS on EMMA prior to the time of first execution of trades in a new issue after the bond sale before imposing the proposed new regulatory requirement.