• Describe any negative effects the proposal would have on the protection of municipal issuers, conduit borrowers, investors, the public interest and the fair and efficient operation of the municipal market.

• Should transactions involving advice provided, or payments made, to conduit borrowers be treated differently under this proposal than those with respect to municipal issuers and other municipal entities?

• Would it be beneficial for the MSRB to require other disclosures to be made on EMMA, such as an underwriter’s or municipal advisor’s fees and scope of work?

• Should disclosures of payments be limited solely to the identity of the payor or payee and the purpose of the payment, or should the amount of payment or additional information be included? If the amount is to be disclosed, should any in-kind or quid-pro-quo payments be disclosed based on their value, or would descriptive disclosures of such payments be acceptable?

• The proposal would include disclosure of payments related to closely related transactions, which is not defined but would include transactions involving swaps or investments of bond proceeds, among other things. What examples of transactions should or should not be considered as closely related transactions, and are there any standards that could be used to define closely related transactions?

• Should the proposal exempt from disclosure requirements commercially reasonable payments to third parties providing standard services to an underwriter or muni advisor in the normal course of doing business, such as payments for copy, analytic, design, printing or electronic publishing? Should exemptions include payments to suppliers of office equipment or other goods, or enterprises performing bona fide standard functions at commercially reasonable rates? Are there any standards that should be used to more precisely define these kinds of exemptions?

• How and when should disclosures be made? Should disclosures related to new muni bonds be made on EMMA as the issue goes to market? Should all disclosures, or just those that relate to municipal financial products or ongoing municipal advisory business, be made periodically, similar to those on the quarterly forms on political contributions filed under Rule G-37?

• California, Florida, New Jersey, Texas and other states require issuers to submit information about fees and other costs associated with in-state securities offerings. Should the MSRB permit issuers to voluntarily submit to EMMA copies of these state filings? Or should the MSRB develop a standardized form that would permit issuers throughout the country to voluntarily disclose amounts paid to all transaction participants and service providers, including bond counsel and trustees, as well as other transaction expenses?

• To what extent, if any, would third-party payment information not be available to dealers and muni advisors? Do dealers and muni advisors already retain this information in records for their other regulatory, risk mitigation or financial record-keeping purposes?

• Beginning on Aug. 2, underwriters will have to disclose these payments to muni issuers. The MSRB has proposed a rule that would require muni advisors to disclose such payments to issuers. What would be the incremental additional burden of having dealers and muni advisors make the disclosures on EMMA as well as to issuers?

• Are there alternative methods the MSRB should consider to providing protections from conflicts that would be more effective and-or less burdensome?

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