May 2, 2019

Via Email to [email protected]
Vanessa Countryman
Acting Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549

Re: File No. SR-MSRB-2019-07 (Release No. 34-85551)

Dear Ms. Countryman,

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates this opportunity to comment on the Municipal Securities Rulemaking Board’s (“MSRB”) Notice of Filing of a Proposed Rule Change to Amend Rules G-11 and G-32 and Form G-32 Regarding a Collection of Data Elements Provided in Electronic Format to the EMMA Dataport System in Connection With Primary Offerings (the “proposed rules” or the “MSRB proposal”).2 The MSRB proposal results from a retrospective review of primary market offering practices in the municipal securities market initiated by the MSRB over two years ago.3 We support the MSRB’s commitment to engaging in a retrospective review of its rules to ensure that they are responsive to changes in the municipal securities market and in the policymaking, economic, stakeholder, and technological environment.

SIFMA has appreciated the opportunity to provide input as the MSRB considered changes to the rules governing primary market offering practices.4 We also appreciate that the MSRB, recognizing that many current market practices have been effective, incorporated our input into the current proposal. For example, we support the Rule G-11 amendment requiring senior syndicate manager to communicate, at the same time, to all syndicate and selling group members when the issue is free to trade. As we have said before, a standardized process for issuing a free to trade wire is consistent with the MSRB’s original intent behind Rule G-11 and does not significantly burden senior syndicate managers because wire communications are already standard market practice. Our comments below focus primarily on the role the MSRB can play to ensure a successful and least burdensome implementation of the final rules.