WASHINGTON — The National Association of Bond Lawyers is questioning whether a Municipal Securities Rulemaking Board proposal to specially designate issuers that undertake any of four types of voluntary initiatives may have the unintended effect of misleading investors about the creditworthiness of the issuers' securities.

In a seven-page comment letter filed with the Securities and Exchange Commission late Friday, NABL was particularly concerned about two of the four voluntary undertakings. The group warned that giving prominence to issuers on the MSRB's EMMA system that either adhere to generally accepted accounting principles established by the Governmental Accounting Standards Board, or receive certificates of achievement from the Government Finance Officers Association, "could lead investors to form mistaken impressions regarding the soundness or quality of the disclosure available for [their] municipal securities."

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