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Proposed Rule Change Consisting of Amendments to MSRB Rule G-40, on Advertising by Municipal Advisors, and MSRB Rule G-8, on Books and Records

Summary

SIFMA provided comments to the Securities and Exchange Commission (SEC) on the Municipal Securities Rulemaking Board’s (MSRB’s) Filing of a Proposed Rule Change Consisting of Amendments to MSRB Rule G-40, on Advertising by Municipal Advisors, and MSRB Rule G-8, on Books and Records.

PDF

Submitted To

SEC

Submitted By

SIFMA

Related Committee(s)

  • Municipal Securities Committee

Date

7

March

2023

Excerpt

March 7, 2023

VIA ELECTRONIC SUBMISSION
Vanessa A. Countryman
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: File Number SR–MSRB–2023–01; Notice of Filing of a Proposed Rule Change Consisting of Amendments to MSRB Rule G-40, on Advertising by Municipal Advisors, and MSRB Rule G-8, on Books and Records

Dear Ms. Countryman,

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates this opportunity to provide input to the Securities and Exchange Commission (“SEC”) on the Municipal Securities Rulemaking Board’s (“MSRB’s”) Filing of a Proposed Rule Change Consisting of Amendments to MSRB Rule G-40, on Advertising by Municipal Advisors, and MSRB Rule G-8, on Books and Records (the “Filing”).2

We urge the SEC to disapprove this Filing. The Filing incorporates significant rule changes that commenters were not given opportunity to comment on to the MSRB prior to the filing of the proposed amendments with the SEC. SIFMA members believe that:

• MSRB Rule G-40 will be unnecessarily complicated by including solicitor municipal advisors.

• Municipal advisor testimonials by third parties should be permitted, in order to harmonize MSRB G-40 with the Investment Advisers Act3 as well as Rule G-21 covering brokers, dealers, and municipal securities dealers.

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1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).

2 88 Fed. Reg. 9580 (Feb. 14, 2023).

3 Investment Advisors Act of 1940 (54 Stat. 847, 15 U.S.C. 80b-1 – 80b-2).

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