In a comment letter filed with the Municipal Securities Rulemaking Board (MSRB), the Securities Industry and Financial Markets Association (SIFMA) expressed its support for the MSRB’s ‘s development of an internet-based public access portal to provide free access to official statements and advance refunding documents. SIFMA also supports expansion of the system to accommodate secondary market disclosure if the Securities and Exchange Commission revises the relevant rule to provide for a centralized electronic submission and dissemination model.
“The electronic delivery model promotes efficiency in the marketplace and allows investors to easily access official statements, which enhances disclosure,” said Leslie Norwood, managing director and associate general counsel at SIFMA. “We continue to support this initiative and believe it is beneficial to municipal market participants.”
In response to the MSRB’s request for comments on specific issues related to the proposal, SIFMA notes that the “access equals delivery” notice for municipal securities should appear on the confirmation, using brief, generic language directing the customer to the web address for official statements. In addition, the letter requests clarification on whether or not commercial paper is excluded from the definition of new issue municipal securities, as SIFMA believes an official statement should not be required for each rollover. Finally, SIFMA recommends coordinating the implementation of a requirement to transmit information at the time of signing a bond purchase agreement with successful testing of the new Depository Trust and Clearing Corporation New Information Dissemination Service to allow for straight-through processing.
