SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Municipal Securities Rulemaking Board’s (MSRB’s) notice of filing of a proposed rule change consisting of amendments to Rule G-16 on periodic compliance examination and Rule G-9 on preservation of records, SR-MSRB-2011-19.  While SIFMA supports the proposed amendments to Rule G-16, which would allow FINRA and the MSRB to establish a risk-based compliance program consistent with FINRA’s requirement for cycle examinations of all other FINRA members, SIFMA does not support the proposed amendments to Rule G-9, which would extend certain record keeping requirements from three years to four years.  SIFMA believes that such a change is not warranted to support the proposed changes to the frequency of the cycle examinations.