SIFMA provides comments to the Securities and Exchange Commission (SEC) regarding a proposed rule change by the Municipal Securities Rulemaking Board (MSRB) that would increase the amount of information currently collected and made transparent by the MSRB on municipal Auction Rate Securities (ARS) and Variable Rate Demand Obligations (VRDOs), Release No. 34-61793; File No. SR-MSRB-2010-02. SIFMA feels strongly that broker dealers are not the appropriate parties to provide this information to the Electronic Municipal Market Access (EMMA) as they are not a party to the requested documents, they are being asked to disclose information which may not be within their knowledge and the requirements will be extremely burdensome for them. SIFMA recommends conducting a cost benefit analysis on the cumulative impact of several rules on broker dealers.