SEC Initiates Proceedings to Determine Whether to Approve Proposed Rule Changes Related to "Time of Trade Disclosures", "Sophisticated Muni Market Professionals", and "Suitability" (with Lofchie Comment)

On September 17, 2013, the MSRB filed with the SEC a proposed rule change consisting of new MSRB Rule G-47 ("Time of Trade Disclosures"), new MSRB Rules D-15 and G-48 ("Relating to Sophisticated Muni Market Professionals"), and amendments to MSRB Rule G-19 ("Suitability"). The SEC received two comment letters in response to the proposed rule change, to which letters the MSRB responded on January 14. The SEC is publishing this order to solicit additional input from interested persons and to institute proceedings to determine whether to approve or disapprove the proposed rule change.

Lofchie Comment:In the ordinary course, these rule changes seem significant enough to warrant a higher number of comments. While the financial industry is no doubt exhausted with trying to keep up with rule changes, it would seem worthwhile for those that are firms trading in the munis markets to provide feedback as to the MSRB suitability proposals.

See: SEC Release No. 34-71326.