SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Municipal Securities Rulemaking Board’s (MSRB’s) notice of filing of proposed new Rule A-11, on municipal advisor assessments, and new Form A-11-Interim, File No. SR-MSRB-2011-08.  The MSRB has proposed to levy an assessment on municipal advisors in order to partially defray the costs of regulating municipal advisors under the MSRB’s authority provided by the
Dodd‐Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). While SIFMA supports the notion of allocating the MSRB’s expenses fairly across all regulated entities, including brokers, dealers, municipal securities dealers and municipal advisors, SIFMA has several serious concerns with the MSRB proposal, and urges the SEC to withhold approval of the proposed rule in its current form until these concerns are addressed.