SIFMA Submits Comments to the MSRB on Retail Order Periods

SIFMA submitted the attached comments to the MSRB on revised draft rule amendments and on a revised draft interpretive notice on retail order periods (see MSRB 2012-50) which propose amendments to MSRB Rules G-11 (on primary offering practices), G-8 (on books and records), and G-32 (on disclosures in connection with primary offerings), as well as an interpretive notice concerning the application of MSRB Rules G-17 and G-30 to retail order periods. SIFMA stated that it supports the proposed rule changes to the extent they would protect dealers that "follow issuers' instructions, clarify issuer terms and conditions, and require timely notice of retail order period terms and conditions to all syndicate and selling group members."

Click here to view comment letter in full (links externally to SIFMA website).