SIFMA provides comments to the Securities Exchange Commission (SEC) on the Municipal Securities Rulemaking Board’s (MSRB) proposed rule change consisting of a proposed interpretive notice applying MSRB Rule G-17 to underwriters of municipal securities.

SIFMA strongly supports the principle of fair dealing embodied in MSRB Rule G-17 and believes the fair dealing standard is critical to ensuring that municipal underwritings are conducted with commercial honor and according to high ethical principles, and has served to protect issuers, investors and the municipal securities market. However, SIFMA has concerns about the timing of the Proposed Interpretive Notice, as well as the prescriptive manner in which it would impose on underwriters open-ended, duplicative and potentially conflicting obligations.