SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on a proposal to collect information on 529 College Savings Plans (529 plans), MSRB Notice 2011-33.  While SIFMA has general concerns that no other investment products (tax-advantaged or otherwise – such as mutual funds, exchange traded funds, equities, or variable insurance products) are required to provide the proposed type of product information to any regulator, SIFMA supports the MSRB’s efforts to collect and disseminate certain market data about 529 plans from primary distributors and specifically believes that the MSRB should consider a rule change to permit the dissemination of plan disclosure documents electronically, as it does for other municipal securities.