January 11, 2021

VIA ELECTRONIC SUBMISSION

Ronald W. Smith
Corporate Secretary
Municipal Securities Rulemaking Board
1300 I Street NW, Suite 1000
Washington, DC 20005

Re: MSRB Notice 2020-19 – Input on Strategic Goals and Priorities

Dear Mr. Smith,

The Securities Industry and Financial Markets Association (SIFMA)1 appreciates this opportunity to comment on the Municipal Securities Rulemaking Board’s (MSRB) request for input on its strategic goals and priorities. We welcome this opportunity for a constructive conversation on the direction of the MSRB, particularly at the start of Mark Kim’s tenure as CEO and his outreach to various stakeholders. Below we provide high-level feedback on particular priorities identified by Mr. Kim as they relate to the MSRB’s mission.

I. Rulebook Modernization – It Should be a Holistic Review

We support the MSRB’s strategic goal to modernize its rulebook by updating the interpretive guidance to ensure it remains relevant and reflects current market practices.2 However, the goal should be much broader than that. Now is the opportune time to review the rulebook holistically and we offer four considerations. First, we appreciate the MSRB’s recent efforts to invite feedback from  stakeholders early in the rulemaking process, and we encourage the MSRB to continue this practice to try to ensure that the compliance and operational challenges are identified and addressed ahead of time. We do note that some of these challenges are only able to be identified when coding begins after specifications are released for new systems or compliance systems are developed and put into place, and appreciate working with the MSRB on these concerns when they are brought to light.