SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed changes to Rule G-8, Books and Records, Rule G-9, Preservation of Records, and Rule G-34, CUSIP Numbers and New Issue Requirements, to Improve Transaction Reporting of New Issues,  File No. SR-MSRB-2007-08.  The Municipal Securities Rulemaking Board (MSRB) submitted the proposal to the SEC on January 11, 2008. SIFMA fully supports increased price transparency in the municipal marketplace and supports development of The Depository Trust and Clearing Corporation’s (DTCC) New Issue Information Dissemination Service (NIIDS).  However, SIFMA does not support the implementation dates for NIIDS testing and mandatory use.