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Proposal to Require Trade Reporting for Proprietary Desk Transactions

Summary

SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on a proposal for proprietary desk transactions to be reported to the MSRB’s Real-Time Transaction Reporting System (RTRS) as customer transactions under MSRB Rule G-14, MSRB Notice 2008-19.  SIFMA shares concerns that the proposal would create new inconsistencies and would result in interpretive issues involving the treatment of the proprietary desk as a customer that would produce significant problems of implementation.

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Date

5

June

2008

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