SIFMA provides comments to the Securities and Exchange Commission (SEC) on the proposed rule changes filed by the Municipal Securities Rulemaking Board (MSRB) to MSRB Rules G-8, G-11 and G-32 to include provisions specifically tailored for retail order periods, File No. SR-MSRB-2013-05.

In prior comments to the MSRB on this issue, SIFMA suggested that concerns raised about retail order periods could be addressed through the enforcement of existing MSRB guidance. Now the MSRB has decided to reorganize some of its interpretive guidance associated with MSRB Rule G-17 into new or revised rules. Consequently, SIFMA supports the proposed rule changes to the extent they would protect dealers that follow issuers’ instructions and require timely notice of retail order period terms and conditions to all syndicate and selling group members, as well to investors through the MSRB’s Electronic Municipal Market System (EMMA).

However, the MSRB has not put forth the least burdensome way to achieve certain regulatory ends contained in its proposal – ends that SIFMA supports. SIFMA believes several of the concepts contained in the MSRB’s proposal could be implemented in a less costly and burdensome way – and urge the SEC to adopt the less burdensome approach put forth by SIFMA.