SUMMARY
SIFMA provided input to the Securities and Exchange Commission on the Proposed Rule Change to Amend and Restate the Municipal Securities Rulemaking Board’s August 2, 2012 Interpretive Notice Concerning the Application of Rule G-17 to Underwriters of Municipal Securities. Although SIFMA recognizes the modifications that the MSRB has made to the rule based, in part, upon our comments to MSRB, SIFMA requests that the SEC disapproves of this Filing until such time that the MSRB amends the Filing to address our further comments described herein.