SIFMA Urges SEC to Improve Bank Muni Dealer Registration Forms

SIFMA called on the SEC to simplify the registration and deregistration forms—MSD ("Application") and MSDW ("Notice of Withdrawal")—that bank municipal securities dealers ("MSDs") are required to file.

In a letter responding to an SEC request for comment, SIFMA expressed support for the Commission’s proposed technical and administrative revisions to simplify the forms’ instructions and eliminate outdated requirements. SIFMA noted that some changes—such as replacing "periodically" with "promptly" in certain instructions—may not add meaningful clarity. The Association urged the SEC to go further by (i) enabling electronic filing and amendments, (ii) making filed forms publicly accessible through EDGAR, and (iii) allowing filers to maintain a single current version. SIFMA argued that these changes would reduce compliance risks and administrative burdens, particularly for MSDs that must frequently update their filings.

SIFMA also pressed the SEC to coordinate with the Office of the Comptroller of the Currency and other federal financial regulators to address duplicative reporting requirements for municipal securities market participants. SIFMA highlighted overlapping data collection forms across multiple forms—such as MSD-4, MSD-5, and various FINRA and MSRB forms—that request similar information on dealers and associated persons. SIFMA recommended pursuing a unified electronic filing platform or, at minimum, greater connectivity among regulators’ databases to improve efficiency and transparency.