WASHINGTON — The Municipal Securities Rulemaking Board is requesting feedback on, among other things, whether its rules impose undue burdens on market participants, and how those burdens could be alleviated.
In a notice issued Tuesday, the board is asking dealers, municipal advisors, issuers and investors to submit comments about whether any of the rules or interpretive notices in its roughly 300-page rule book should be reconsidered.
The board wants to know how rules could be improved or made more efficient or effective.
"While the MSRB takes steps to consider evolving market conditions in its rulemaking, it is soliciting comments to determine whether any rules or guidance should be revised or restated due to changes in market practices or conditions, or to be more-closely aligned with rules of other self-regulatory organizations or government entities," the board said in its release.
General feedback is welcome, but the release asked seven specific questions:
- Are revisions needed to address changing market practices and conditions? What revisions are appropriate?
- Should any rules or interpretive notices be consolidated?
- Are any rules no longer applicable? If so, why?
- Do any rules impose undue burdens? If so, how could those burdens be lessened, or are there alternatives that should be considered?
- Do any rules fail to accomplish their purpose?
- Could any rules be modified to make compliance easier?
- Should the board consider new rules to address current market conditions or practices?
The release asks market participants to remember that federal statutes require the MSRB to design its rules so as to prevent fraudulent and manipulative practices, promote just and equitable principles of trade and foster a free and open muni market.
Comments are due Feb. 19.
Tuesday's release comes two weeks after MSRB executive director Lynnette Kelly announced a multi-year effort to review the effectiveness, efficiency, costs and benefits of MSRB rules.
"Instead of just creating more rules, we are taking the time to look at the existing rule book," Kelly said at that time.
"The default in the past was, let's write rules. Now, we are careful and thoughtful about exploring alternatives."
