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Regulatory Comments and Recommendations

Letter to the Securities and Exchange Commission (SEC) Investor Advocate
November 8, 2021
MSRB CEO Mark Kim sent a letter to the SEC's Office of the Investor Advocate in response to a request for the MSRB to identify products and practices within the municipal securities market that may have an adverse impact on investors.
Read the letter.

Comment Letter to the Governmental Accounting Standards Board (GASB) on its April 6, 2021 Exposure Draft—"The Annual Comprehensive Financial Report.”
July 9, 2021
The MSRB submitted a comment letter supporting GASB's response to stakeholder concerns about the acronym associated with the term comprehensive annual financial report and commends its efforts to change it.
Read the letter.

Comment Letter to the Securities and Exchange Commission (SEC) on its Concept Regulatory Framework for Electronic Trading Platforms
March 1, 2021
The MSRB submitted a comment letter to the SEC on its concept proposal on the regulatory framework for electronic platforms that trade corporate debt and municipal securities.
Read the letter.

Comment Letter to the Securities and Exchange Commission (SEC) on its Proposed Exemptive Order for Registered Municipal Advisors
December 9, 2019
The MSRB submitted a comment letter to the SEC on its proposed exemptive order that would permit registered municipal advisors to engage in certain activities in connection with the direct placement of municipal securities without registering as a broker.
Read the letter.

Letter to the Securities and Exchange Commission (SEC) Investor Advocate
November 12, 2019
MSRB Interim Chief Executive Officer and Chief Financial Officer Nanette D. Lawson sent a letter to the SEC's Office of the Investor Advocate in response to a request for the MSRB to identify products and practices within the municipal securities market that may have an adverse impact on investors.
Read the letter.

Letter to the Securities and Exchange Commission (SEC) Investor Advocate
October 19, 2018
MSRB President and CEO Lynnette Kelly sent a letter to the SEC's Office of the Investor Advocate in response to a request for the MSRB to identify products and practices within the municipal securities market that may have an adverse impact on investors.
Read the letter.

Letter to the Securities and Exchange Commission (SEC) on its Strategic Plan
July 25, 2018
MSRB President and CEO Lynnette Kelly submitted a comment letter on behalf of the MSRB to provide feedback to the SEC on its draft Fiscal Years 2018-2022 Strategic Plan. The letter highlights areas under the Strategic Plan in which the MSRB and SEC can share information, data and expertise that inform, among other items, rulemaking efforts, technology to support disclosure and the appropriate enforcement of MSRB rules.
Read the comment letter.

Letter to the Securities and Exchange Commission (SEC) Investor Advocate
October 17, 2017
MSRB Executive Director Lynnette Kelly sent a letter to the SEC's Office of the Investor Advocate in response to a 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 to the Governmental Accounting Standards Board (GASB) 
September 7, 2017
The MSRB submitted a comment letter to the GASB in response to the organization's ongoing research and outreach efforts on the topic of disclosure by state and local government bond issuers related to debt, including direct borrowings and direct placements.
Read the comment letter.

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 an 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