SIFMA provides comments to the Securities and Exchange Commission (SEC) on  SEC guidance concerning proposed rule changes filed by self-regulatory organizations (SRO), SEC Release No. 34-58092.  The SEC guidance relates to rule 19b-4 under the Securities Exchange Act of 1934. SIFMA is concerned that the New Guidance Release will increase the likelihood of inefficient or otherwise potentially deficient SRO rulemaking. SIFMA also questions why the Commission has rescinded the delegated authority under which the Director of the Division could abrogate immediately effective SRO rule filings under Section 19(b)(3)(C) of the Exchange Act. SIFMA believes that all new rulemaking and guidance should be subject to formal public comment.