Public Commentary

The MSRB periodically provides public comment on issues relating to the municipal securities market. This comment can be in the form of letters to Congress and government agencies, Congressional testimony or opinion articles in news publications. 

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Congressional Testimony and Letters

Examining the Agenda of Regulators, Self-Regulatory Organizations and Standards-Setters for Accounting, Auditing and Municipal Securities
U.S. House Financial Services Subcommittee Hearing
September 22, 2016
Read written testimony submitted by the MSRB.

Letter to Congress on MSRB's Implementation of the Dodd-Frank Wall Act
September 19, 2016
MSRB Board Chair Nat Singer sent a letter on behalf of the MSRB to the Senate Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services to provide an update on the MSRB's implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The letter outlines the MSRB's development of a regulatory framework for municipal advisors and details the MSRB's municipal entity protection efforts. 
Read the letter.

Letter to Congressional Task Force on Economic Growth in Puerto Rico
September 2, 2016
MSRB Executive Director Lynnette Kelly sent a letter on behalf of the MSRB to the Congressional Task Force on Economic Growth in Puerto Rico to discuss the importance of a robust, transparent and fair municipal market for sustained economic growth in Puerto Rico. The letter outlines a set of principles, informed by MSRB regulatory, transparency and education initiatives, recommended for consideration by Puerto Rico, its bonding authorities and any municipal securities issuer seeking to enhance investor confidence.
Read the letter.

The Impact of the Dodd-Frank Wall Street Reform and Consumer Protection Act on Municipal Finance 
U.S. House Financial Services Subcommittee Hearing 
July 20, 2012
View the Committee's archive video of the live hearing.
Read written testimony submitted by the MSRB.

Enhanced Investor Protection after the Financial Crisis 
Senate Committee on Banking, Housing and Urban Affairs Hearing 
July 12, 2011
Read the MSRB's written testimony.

Gaps in Municipal Securities Regulatory Structure
Senate Committee on Banking, Housing and Urban Affairs Hearing
March 26, 2009
Read the MSRB’s written testimony.

Letter to Congress on Comprehensive Rules for Intermediaries
February 6, 2009
The MSRB submitted a letter to Congress with recommendations to develop a regulatory structure that governs municipal market participants that provide certain key services to state and local government issuers.
Read the letter.

Regulatory Comments and Recommendations

Comment Letter to the Securities and Exchange Commission on Proposed Amendments to Exchange Act Rule 15c2-12
April 14, 2017
The MSRB submitted a comment letter to the SEC on proposed amendments to require issuers and obligated persons to post event notices that would include their incurrence of a material bank loan or direct purchase of municipal securities.
Read the comment letter.

Letter to the Securities and Exchange Commission (SEC) Investor Advocate
November 3, 2016
MSRB Executive Director Lynnette Kelly sent a letter on behalf of the MSRB to the SEC's Investor Advocate in response to a request for the MSRB's perspective on products and practices within the municipal securities market that may have an adverse impact on retail investors. The MSRB's letter identifies disclosure practices, price fairness and transparency, types of ownership of municipal bonds and senior investor protection as areas of particular concern.  
Read the letter.

Letter to the Governmental Accounting Standards Board (GASB)
April 25, 2016
In response to the GASB's research on debt disclosures, MSRB Executive Director Lynnette Kelly advised the organization of the MSRB's efforts to increase voluntary disclosure by state and local government bond issuers of additional debt and debt-like obligations. The MSRB believes such disclosure is essential to foster a fair and efficient municipal securities market. 
Read the letter.

Letter to Securities and Exchange Commission Investor Advocate
October 30, 2015
MSRB Executive Director Lynnette Kelly sent a letter on behalf of the MSRB to the Securities and Exchange Commission's Investor Advocate in response to its request for the MSRB to identify products and practices within the municipal securities market that may have an adverse impact on retail investors.
Read the letter.

Comment Letter on Securities and Exchange Commission Rule 15c2-12
January 20, 2015
The MSRB submitted a comment letter urging the SEC to revisit its municipal market disclosure rule, Rule 15c2-12, and consider potential changes to improve its operation and reflect current market practices. 
Read the comment letter.

Comment Letter on Securities and Exchange Commission Draft FY 2014-2018 Strategic Plan
March 19, 2014
MSRB Executive Director Lynnette Kelly submitted a comment letter on behalf of the MSRB in support of the municipal market goals of the SEC's draft strategic plan for fiscal years 2014-2018.
Read the comment letter. 

Comment Letter on Securities and Exchange Commission Proposed Regulation Systems Compliance and Integrity
June 28, 2013
The MSRB submitted a comment letter on the SEC’s proposed rule to require certain key market participants to have comprehensive policies and procedures in place surrounding their technological systems.
Read the comment letter.

Potential Improvements to Market Structure for Municipal Securities 
Securities and Exchange Commission Roundtable on Fixed Income Markets
April 16, 2013
MSRB Executive Director Lynnette Kelly participated in a roundtable discussion on potential improvements to the market structure for municipal securities at the SEC.
Read the written statement submitted by the MSRB.

Comment Letter on the Volcker Rule
January 31, 2012
The MSRB submitted a letter to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the SEC urging expansion of the draft “Volcker Rule” to include governmental obligations exemption to include all municipal securities.
Read the comment letter.

Letter to the Securities and Exchange Commission on Municipal Advisory Activities
November 9, 2011
The MSRB submitted a letter to the SEC on the activities of municipal advisors to assist the SEC with finalizing its definition of “municipal advisor.”
Read the letter.

Letter to the Securities and Exchange Commission on Municipal Market Disclosure
August 8, 2011 
The MSRB submitted a letter to the SEC with recommendations on municipal market disclosure that would provide investors with additional information about municipal securities in both the primary and secondary markets.
Read the letter.

Comment Letter to the Securities and Exchange Commission's Proposed Municipal Advisor Registration Rules
February 22, 2011
The MSRB submitted a comment letter on the SEC’s proposed rules to establish a registration regime for municipal advisors.
Read the comment letter


Opinion Articles

Op-ed in The Bond Buyer on Pay-to-Play Practices
August 4, 2016
MSRB Board Chair Nat Singer published an op-ed in The Bond Buyer, the news outlet covering the municipal market, addressing the MSRB's recent rulemaking to sever the link between giving of political contributions and awarding of municipal advisory business.
Read the op-ed.

Op-ed in Governing Magazine on Bank Loan Disclosure
May 13, 2016
MSRB Executive Director Lynnette Kelly published an op-ed in Governing, a national magazine for state and local government leaders, warning of the risks of inadequate bank loan disclosure by municipal securities issuers.
Read the op-ed.