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June 12, 2013

SIMFA responded with additional proposals to MSRB's request for comment on its proposed sophisticated municipal market professional rules.SIMFA stated that it continues to support MSRB's proposed efforts to clarify Rule G-17 and still supports the requirement that proposed Rule G-48 reference a firm's reduced obligation to SMMPs by cross-referencing with proposed Rule G-48. However, SIFMA also would like to see several additional proposals simultaneously implemented by the MSRB. The SIFMA requests include: Proposed Rule D-15: Expanding the definition of Sophisticated Municipal Market

July 26, 2013

SIFMA issued a comment letter as to the level of effort that a broker-dealer should be required to undertake in order to obtain an execution of legally sufficient quality in the municipal bond markets. The comment letter was in reports to the July 31 SEC Report on the Municipal Securities Markets, asserting that retail customers in the municipal bond markets are disadvantaged in execution, pricing, and disclosure as they do not have access to the same information as dealers and institutional customers. In this regard, the SEC had recommended a rule change that would require municipal bond

November 12, 2013

SIFMA submitted comments to the SEC regarding the proposed changes to MSRB Rule G-47 ("Time of Trade and Disclosure Obligations") and Rule G-19 ("Suitability of Recommendations and Transactions; Discretionary Accounts"), and proposed new MSRB Rules D-15 and G-48 (on sophisticated municipal market professionals) and the deletion of the interpretive guidance that is being superseded by these rule changes. According to the letter, SIFMA supports the MSRB's efforts to clarify its rules by reorganizing or eliminating the interpretive guidance associated with Rule G-17 into new or revised rules that

March 13, 2014

SIFMA submitted comments to the MSRB regarding the draft best execution rule, including the exception for transactions with sophisticated municipal market professionals. SIFMA stated that it supports an execution standard for the municipal market that is structurally similar to FINRA Rule 5310 ("Publication of Transactions and Quotations"). In the letter, SIFMA disagrees with applying equity-based execution standards to the municipal market. Instead, SIFMA argued that rules and standards involving execution should reflect their "fundamental limitations and objects to rules that implicitly or

September 29, 2014

SIFMA submitted comments to the SEC regarding proposed amendments to the MSRB's rules pertaining to best execution of municipal securities and transactions with Sophisticated Municipal Market Professionals ("SMMP"). In the letter, SIFMA noted that it supports raising the execution standard in the municipal market for retail customers in a way that reflects the current market structure and unique characteristics of the municipal market. In addition, SIFMA expressed support for the proposed revisions to MSRB Rules G-18 (presently reserved) and G-48 ("Transactions with Sophisticated Municipal