SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC’s order instituting proceedings to determine whether to disapprove a proposed rule change, as modified by Amendment No. 2, consisting of interpretive notice applying Municipal Securities Rulemaking Board (MSRB) Rule G-17 to Underwriters of Municipal Securities, File Number SR-MSRB-2011-09.  SIFMA strongly supports the MSRB’s efforts to provide guidance on the application of Rule G-17 to underwriters, but is concerned about the timing of the proposal and the vague and overbroad nature of certain requirements that the proposal would impose on underwriters.