SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed changes to Rule G-23: Activities of Financial Advisors, File No. SR-MSRB-2011-03.  Although SIFMA supports certain portions of the proposed amendments, SIFMA believes certain aspects of the proposed changes may have adverse consequences to the market for municipal securities and municipal issuers themselves.  SIFMA describes the most significant potential adverse consequences.  Overshadowing all of this is the fact that there remains considerable uncertainty over the scope of the fiduciary standard for advisors to municipal entities.