SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed amendments to rule 206(4)(5), the Investment Adviser Pay-to-Play rules which regulates an investment adviser’s interactions with governmental clients such as public pension funds. That rule had just been finalized in July 2010 after an eleven-month comment and amendment process.  The most-recent amendments – proposed in November 2010 – would make substantial changes to the Investment Adviser Pay-to-Play Rule, including replacing the current category of permitted ‘regulated persons’ with registered “municipal advisors” (the definition of which is subject to a separate, still-pending rulemaking), and shifting regulatory jurisdiction over broker-dealers who solicit fund investments from government entities on behalf of investment advisers to the MSRB from FINRA.