SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on the MSRB’s Concept Proposal (Proposal) to strengthen account opening and supervisory practices of dealers effecting online municipal securities transactions with individual investors, MSRB Notice 2012-41.  SIFMA generally supports the MSRB’s goals of increasing the likelihood that individual investors who trade municipal securities online understand the features and risks of such investments. However, SIFMA objects to certain key aspects of the Proposal and suggests more reasonable alternatives to achieve the Proposal’s stated objectives.