SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Municipal Securities Rulemaking Board’s (MSRB) proposed fee increases, Release No. 34-63095, the “Notice of Filing of Proposed Rule Change Consisting of Amendments to Rule A–13 To Increase Transaction Assessments for Certain Municipal Securities Transactions Reported to the Board and To Institute a New Technology Fee on Reported Sales Transactions.”

The MSRB is responsible for a number of initiatives that are valuable to the municipal bond market, and SIFMA recognizes that the MSRB needs a stable and robust funding source to cover its expenses. However, the fees proposed in the Notice would be borne by municipal market participants in an unfair manner, and the MSRB has been less than fully transparent with regard to the uses of additional revenue and the manner in which the fee increases proposed in the Notice were determined. SIFMA urges the SEC to reject the fee proposal in the Notice, and urges the MSRB to work with its dealer, bank and advisor members and the SEC to determine an alternative fee structure that is fair and transparent.