SIFMA Submits Comments on Disclosure Suitability for Sophisticated Municipal Market Professionals

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and G-48 (on sophisticated municipal market professionals) and the deletion of the interpretive guidance that is being superseded by these rule changes.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 highlight core principles, as well as harmonizing Rule G-19 with FINRA Rule 2111 ("Suitability").

As the multiple rule proposals are interrelated, SIFMA suggests packaging them into a single filing with the SEC. Additionally, SIFMA believes that clarifications are needed on a number of topics, including detailing the circumstances when a preliminary official statement can satisfy a dealer's time of trade disclosure obligations for a new issue, and clarifying that information barriers are not required to be breached.

See: SIFMA Comment Letter.