SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) in regard to MSRB Notice 2009-20, in which the MSRB requests comment on its proposed draft amendments to Rule G-11, on new issue syndicate practices, and Rule G-12, on uniform practice, which would accelerate the settlement of syndicate accounts and secondary market trading accounts and the payment of designations. SIFMA understands that the proposals are intended to reduce the exposure of the syndicate and secondary market trading account members to the potential deterioration in the credit of the syndicate or account manager, and applauds the MSRB for its efforts to address this issue. SIFMA supports the proposed change to Rule G-12, but wishes to express some concerns over the proposed changes to Rule G-11.