SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposed rule that would establish a permanent registration program for municipal advisors under Section 975 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act).  SIFMA believes that the SEC’s proposed rules and proposed interpretative positions regarding municipal advisory activities are overly broad in light of the provisions of Section 975 and Congressional intent.  In addition, SIFMA believes the proposed rules as written would result in more limited and costly services provided by fewer financial institutions to municipal entities and obligated persons; and would subject many currently regulated entities to burdensome, overlapping, duplicative and unnecessary requirements and potential liabilities.