SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed rule changes consisting of proposed changes to Municipal Securities Rulemaking Board (MSRB) Rule G-30, on Prices and Commissions, and the deletion of Rule G-18, on Execution of Transactions. These changes would consolidate MSRB Rule G-18 and Rule G-30, and streamline and codify existing guidance regarding fair pricing currently set forth in interpretive guidance to MSRB Rules G-17 and G-30. The proposed changes would create a single general rule, G-30, on prices and remuneration.

SIFMA is generally supportive of this rule consolidation, which preserves the substance of existing fair pricing requirements. However, in light of the MSRB’s proposed best execution rule for municipal securities and the nexus between execution and pricing, SIFMA believes that these two proposals must be viewed together – the interplay and practical effects between best execution and fair pricing – and therefore requests that the SEC not move forward at this time to allow the MSRB to submit, and allow market participants to comment on, a single filing with the SEC on dealer execution and pricing obligations.