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MSRB Notice 2022-06 – Amendments to Certain Fees for Dealers and Municipal Advisors and Proposing an Annual Rate Card Process

Summary

SIFMA provided comments to the U.S. Securities and Exchange Commission (SEC) on the Municipal Securities Rulemaking Board’s (MSRB’s) Notice 2022-06 and its Filing of a Proposed Rule Change to Amend Certain Rates of Assessment for Rate Card Fees Under MSRB Rules A-11 and A-13, Institute an Annual Rate Card Process for Future Rate Amendments, and Provide for Certain Technical Amendments to MSRB Rules A-11, A-12, and A-13.

PDF

Submitted To

SEC

Submitted By

SIFMA

Related Committee(s)

  • Municipal Securities Committee

Date

2

September

2022

Excerpt

September 2, 2022

VIA ELECTRONIC SUBMISSION
Vanessa A. Countryman
Secretary
Securities and Exchange
Commission, 100 F Street, NE
Washington, DC 20549

Re: File Number SR–MSRB–2022–06; MSRB Notice 2022-06 – Amendments to Certain Fees for Dealers and Municipal Advisors and Proposing an Annual Rate Card Process

Dear Ms. Countryman,

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates this opportunity to provide input to the Securities and Exchange Commission (“SEC”) on the Municipal Securities Rulemaking Board’s (“MSRB’s”) Notice 2022-06 (the “Notice”)2 and its Filing of a Proposed Rule Change to Amend Certain Rates of Assessment for Rate Card Fees Under MSRB Rules A-11 and A-13, Institute an Annual Rate Card Process for Future Rate Amendments, and Provide for Certain Technical Amendments to MSRB Rules A-11, A-12, and A-13 (the “Filing”).3

The Filing amends MSRB Rules to establish a new variable annual fee rate setting process (“Annual Rate Card Process”) for certain fees charged by the MSRB to broker dealers and municipal advisors. SIFMA continues to oppose the Filing because it fails to address the disparity between the relative contributions of broker dealers and municipal advisors. Also, the MSRB’s budget-setting process under the Proposal continues to remain opaque with no opportunity for stakeholder input.

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1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).

2 MSRB Notice 2022-06 (July 29, 2022).

3 87 Fed. Reg. 48530 (August 9, 2022).

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