SIFMA provides comments to the Securities and Exchange Commission (SEC) on the proposed rule changes filed by the Municipal Securities Rulemaking Board (“MSRB”) relating to new MSRB Rule G-45, on Reporting of Information on Municipal Fund Securities, and Form G-45, and amendments to Rules G-8, on Books and Records, and G-9, on Preservation of Records (the Proposal).

In prior comments to the MSRB on this issue, SIFMA has generally been supportive of the MSRB’s desire to collect more comprehensive information relating to 529 College Savings Plans (529 plans) underwritten by brokers, dealers or municipal securities dealers by collecting data directly from such dealers – even though the MSRB will only be able to collect market data on the portion of the 529 plan market for which dealers act in the capacity of underwriter, as well as our belief that the MSRB’s desire to have EMMA to become the research repository for 529 plan investors is an attempt to duplicate other alternative comprehensive data sources for investors. The MSRB has been responsive to comments made by various market participants, and SIFMA believes the Proposal has been tailored to allow the MSRB to better understand and monitor this market. However, SIFMA continues to have some concerns with aspects of the proposal.