SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on three proposed rule changes to MSRB Rule G-3 (MSRB Notice 2013-22):

1. expanding the scope of persons subject to and the substance of the “firm element” of a broker, dealer, or municipal securities dealer’s continuing education requirements [MSRB Rule G-3(h)]; 
2. eliminating the requirement of MSRB Rule G-3(d) for certain firms to appoint at least one Financial and Operations Principal; and 
3. modifying the scope of permissible activities for a Limited Representative – Investment Company and Variable Contracts Products (Limited Representative) in MSRB Rule G-3(a)(ii)(C).

SIFMA supports eliminating the requirement of MSRB Rule G-3(d) for certain firms to appoint at least one Financial and Operations Principal, and modifying the scope of permissible activities for a Limited Representative – Investment Company and Variable Contracts Products (Limited Representative) in MSRB Rule G-3(a)(ii)(C). However, SIFMA believes the proposed changes to MSRB Rule G-3(h), while well-intentioned, require additional consideration and analysis. SIFMA believes the MSRB should reconsider the proposal altogether, and provides preliminary feedback to the proposed changes.