SIFMA called on the MSRB to take no action on Rule G-34 ("CUSIP Numbers, New Issue and Market Information Requirements") and to leave the 2017 amendments in place. As previously covered, the MSRB requested comments on the "CUSIP Requirement," which obligates municipal advisors assisting issuers in the "competitive sale of a new issue of municipal securities to apply for the assignment of a CUSIP number . . . within a specified time frame."
In a comment letter, SIFMA said it is surprising that Rule G-34 is under review only eight months after the 2017 G-34 amendments became effective. According to SIFMA, the MSRB should leave Rule G-34 as is, since the MSRB considered most of the questions raised when it assessed the 2017 G-34 amendments themselves. With respect to the competitive public offerings of notes, SIFMA suggested the MSRB should consider providing limited relief to municipal advisers by requiring the winning underwriter to obtain the CUSIP.
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