SIFMA provides contents to the Securities and Exchange Commission (SEC) on a proposed rule change to amend MSRB Rules G-8, G-11 and G-32 to include provisions specifically tailored for retail order periods, Amendment No 1. to File No. SR-MSRB-2013-05.

SIFMA believes that concerns raised about retail order periods could be addressed through the enforcement of existing MSRB guidance, MSRB Notice 2012-25 (May 7, 2012). Now the MSRB has decided to reorganize some of its interpretive guidance associated with MSRB Rule G-17 into new or revised rules.

Consequently, SIFMA supports the proposed rule changes to the extent they would protect dealers that follow issuers’ instructions and require timely notice of retail order period terms and conditions to all syndicate and selling group members, as well to investors through the MSRB’s Electronic Municipal Market System (EMMA).