All Comments to Notice 2023-11

1. Advisabilitys: Email from Andrew Boyack dated January 9, 2024
2. Academy Securities, Inc.: Letter from Michael Boyd, Chief Compliance Officer, dated February 23, 2024
3. American Securities Association: Letter from Jessica R. Giroux, General Counsel, dated February 26, 2024
4. Amuni Financial, Inc.: Letter from Mike Petagna, President, dated January 8, 2024
5. Anonymous: Letter
6. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated February 26, 2024
7. Clary Consulting Company: Email from Lowell Clary dated February 16, 2024
8. Derivative Advisors: Letter from Elaine M. Philbrick, Principal, dated December 6, 2023
9. Dixworks, LLC: Email from Dennis Dix, Jr. dated February 9, 2024
10. Echo Valley Advisors, LLC: Letter from Julie Needham, President, dated February 23, 2024
11. Herold & Lantern Investments: Letter from Brad Harris, Director of Fixed Income – Municipal Bonds
12. Municipal Capital Markets Group, Inc.: Letter from Fred R. Cornwall, President, dated February 26, 2024
13. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated February 26, 2024
14. Regional Brokers, Inc.: Letter from H. Deane Armstrong, CCO, dated February 26, 2024
15. Ridgeline Municipal Strategies, LLC: Email from Dmitry Semenov dated December 29, 2023
16. Sanderlin Securities LLC: Letter from Matthew Kamler, President, dated January 26, 2024
17. Searle & Co., Inc.: Letter from Robert S. Searle, President, dated February 16, 2024
18. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, Head of Municipal Securities, dated February 26, 2024
19. Shnayder, Yana: Email dated December 13, 2023
20. Siebert Williams Shank & Co., LLC: Letter from Suzanne Shank, President & Chief Executive Officer, and Gary Hall, President of Infrastructure & Public Finance, dated February 26, 2024
21. Speer Financial, Inc.: Letter from Daniel Forbes, President, dated February 20, 2024
22. Stern Brothers: Letter dated February 26, 2024

1. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated December 15, 2023

All Comments to Notice 2023-02

1. AKF Consulting: Letter from Andrea Feirstein, Managing Director, and Mark Chapleau, Senior Consultant, dated April 20, 2023
2. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated April 17, 2023
3. College Savings Plans Network: Letter from Rachel Biar, Nebraska Assistant State Treasurer, NEST 529 College Savings Program Director, Chairman, College Savings Plans Network, dated April 17, 2023
4. Government Finance Officers Association: Letter from Emily Brock, Director, Federal Liaison Center, dated July 21, 2023
5. McLane, Curtis: Email dated April 19, 2023
6. my529: Letter from Richard K. Ellis, Executive Director, dated April 17, 2023
7. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, Head of Municipal Securities, dated April 17, 2023

All Comments to Notice 2022-13

1. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 30, 2023
2. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated January 30, 2023
3. Wulff, Hansen & Co.: Letter from Chris Charles, President, dated December 29, 2022

All Comments to Notice 2021-18

1. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated March 15, 2022

2. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 15, 2022

3. Third-Party Marketers Association: Letter from Donna DiMaria, Chairman of the Board of Directors and Chair of the 3PM Regulatory Committee, dated March 15, 2022

All Comments to Notice 2021-12

1. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated January 19, 2022

2. First River Advisory L.L.C.: Letter from Shelley J. Aronson dated January 18, 2022

3. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 19, 2022

4. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Matthew Roberts, Assistant Vice President, dated January 19, 2022

All Comments to Notice 2021-08

1. American Securities Association: Letter from Christopher A. Iacovella, Chief Executive Officer, dated June 28, 2021

2. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated June 28, 2021

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated June 28, 2021

4. Szaro, Jennifer: Email dated May 17, 2021

All Comments to Notice 2020-19

1. 280 Securities LLC: Letter from Wm. Thomas Lockard, Managing Director, dated January 6, 2021

2, American Bankers Association: Letter from Justin M. Underwood dated January 11. 2021

3. American Securities Association: Kelli McMorrow, Head of Government Affairs, dated January 11, 2021

4. Belton, David F.: Letter

5. Bliss, Evan: Email dated January 13, 2021

6. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated January 11, 2021

7. Ceres, Inc.: Letter from Steven M. Rothstein, Managing Director, Ceres Accelerator for Sustainable Capital Markets, dated January 11, 2021

8. Climate Advisory: Letter from Lisa L. Churchill, Founder, dated January 11, 2021

9. Geos Institute: Email from Tonya Graham dated January 11, 2021

10. Global Legal Entity Identifier Foundation: Letter from Stephan Wolf, CEO, dated January 5, 2021

11. Government Finance Officers Association: Letter from Emily Swanson Brock, Director, Financial Liaison Center, dated January 11, 2021

12. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 11, 2021

13. National Association of State Treasurers: Letter from Shaun Snyder, Executive Director, dated January 11, 2021

14. PFM Financial Advisors LLC: Letter from Leo Karwejna, Managing Director, Chief Compliance Officer, dated January 12, 2021

15. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Bernard V. Canepa, Vice President and Assistant General Counsel, dated January 11, 2021

16. Ugarte, Allyson: Letter dated January 11, 2021

17. XBRL US: Letter from Campbell Pryde, President and CEO, dated January 11, 2021

All Comments to Notice 2020-02

1. Acacia Financial Group, Inc.: Letter from Kim M. Whelan, Co-President, and Noreen P. White, Co-President, dated April 29, 2020

2. Action Center on Race and the Economy, AFSCME, AFL-CIO, Americans for Financial Reform Education Fund, Consumer Federation of America and Public Citizen: Letter dated April 29, 2020

3. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated April 29, 2020

4. Government Finance Officers Association: Letter from Emily Swenson Brock, Director, Federal Liaison Center, dated April 29, 2020

5. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated April 15, 2020

6. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated April 29, 2020

7. National Association of State Auditors, Comptrollers and Treasurers: Letter from Beth Pearce, President, dated April 30, 2020

8.  National Association of State Treasurers: Letter from Shaun Snyder, Executive Director, dated April 28, 2020

9. National Federation of Municipal Analysts: Letter from Nicole Byrd, Chair, dated April 29, 2020

10. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Bernard V. Canepa, Vice President and Assistant General Counsel, dated April 29, 2020

11. Steve Apfelbacher, Renee Boicourt, Marianne Edmonds, Robert Lamb, Nathaniel Singer and Noreen White [former MSRB Board members]: Letter dated April 29, 2020

All Comments to Notice 2019-13

1. Acacia Financial Group, Inc.: Letter from Kim M. Whelan, Co-President, and Noreen P. White, Co-President, dated August 19, 2019

2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated August 23, 2019

3. Columbia Capital Management, LLC: Letter from Jeff White, Managing Member, dated August 19, 2019

4. Crews & Associates, Inc.: Letter from Don Winton, Chief Operating Officer, dated August 23, 2019

5. Ehlers: Letter from Phil Cosson, Ehlers Board Chairman

6. First Kentucky Securities Corp.: Email from Stan Kramer dated August 13, 2019

7. Government Finance Officers Association: Letter from Emily Swenson Brock, Director, Federal Liaison Center, dated August 19, 2019

8. KPM Financial, LLC: Letter from Jay Saunders, Director

9. Kutak Rock LLP: Letter from Joshua P. Meyer dated August 16, 2019

10. Lewis Young Robertson & Burningham, Inc.: Letter from Laura D. Lewis, Principal, dated August 7, 2019

11. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated August 19, 2019

12. Phoenix Advisors, LLC: Letter from David B. Thompson, CEO, dated August 14, 2019

13. Richard Li: Email dated January 29, 2020

14. Robert W. Doty: Letter dated August 19, 2019 

15.Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Bernard V. Canepa, Vice-President and Assistant General Counsel, dated August 19, 2019

16. Speer Financial, Inc.: Letter from Daniel Forbes, President, dated August 19, 2019

17. State of Florida, Division of Bond Finance: Letter from J. Ben Watkins III, Director, dated September 3, 2019

18. Zions Public Finance, Inc. and Zions Bank Public Finance: Letter from James Livingston, Executive Vice President, dated August 14, 2019

All Comments to Notice 2019-08

1. Bernardi Securities, Inc.: Letter from Lou Lamberti, Sr. Vice President, dated May 24, 2019

2. Bloomberg L.P.: Letter from Peter Warms, Senior Manager, Entity and Identifier Services, dated May 28, 2019

3. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated May 28, 2019

4. Dixworks LLC: Letter from Dennis Dix, Jr., dated March 4, 2019

5. Lamont Financial Services Corporation: Letter from Robert A. Lamb, President, dated May 7, 2019

6. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated May 28, 2019

7. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated May 28, 2019

8. Municipal Solutions, Inc.: Letter from Jeffrey R. Smith, President, dated May 28, 2019

All Comments to Notice 2019-01

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated March 5, 2019

2. Regional Brokers, Inc.: Letter from H. Deane Armstrong, CCO, and Joseph A. Hemphill, CEO, dated March 7, 2019

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 6, 2019

All Comments to Notice 2018-29

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated January 15, 2019

2. City of San Diego: Letter 

3. Government Finance Officers Association: Letter from Emily S. Brock, Director, Federal Liaison Center, dated January 15, 2019

4. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 15, 2019

5. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Bernard V. Canepa, Vice President and Assistant General Counsel, dated January 15, 2019

All Comments to Notice 2018-25

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated October 17, 2018; and Letter from Michael Nicholas, Chief Executive Officer, dated November 30, 2018

2. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated October 17, 2018

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated October 17, 2018

4. Springsted Incorporated: Letter from Kathleen A. Aho, President, dated October 17, 2018

All Comments to Notice 2018-22

1. Amuni Financial, Inc.: Letter from Mike Petagna, President, dated October 31, 2018

2. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 13, 2018

3. Emmet & Co.: Email from Robert Ventrice dated September 14, 2018

4. Hartfield, Titus & Donnelly, LLC: Letter from Edward J. Smith, Chief Compliance Officer, and Christopher C. Ferreri, Chief Operating Officer, dated November 13, 2018

5. Headlands Tech Global Markets, LLC: Letter from Matthew F. Andresen, Chief Executive Officer, dated October 26, 2018

6. Regional Brokers, Inc.: Letter from Joseph A. Hemphill, III, Chief Executive Officer, and H. Deane Armstrong, Chief Compliance Officer, dated November 6, 2018

7. RW Smith & Associates, LLC: Letter from Denien Rasmussen, Co-Chief Compliance Officer, Chief Operating Officer, dated November 13, 2018

8. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated November 13, 2018

9. TMC Bonds: Letter from Thomas S. Vales, Chief Executive Officer, dated November 14, 2018

1. Wells Fargo Advisors: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated November 5, 2018

All Comments to Notice 2018-20

1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 27, 2018

2. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated November 28, 2018

3. Securities Industry and Financial Markets Association: Letter from Michael Decker, Managing Director, dated November 27, 2018

All Comments to Notice 2018-19

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated September 14, 2018

2. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated September 17, 2018

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 14, 2018

4. Wells Fargo Advisors: Letter from Robert J. McCarthy, Director of Regulatory Policy, dated September 14, 2018

All Comments to Notice 2018-15

1. Acacia Financial Group, Inc.: Letter from Noreen P. White, Co-President, and Kim M. Whelan, Co-President, dated September 17, 2018

2. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated September 17, 2018

3. C F I: Email from Stephen Holstein dated July 25, 2018

4. Ehlers Associates, Inc.: Letter from Steve Apfelbacher dated September 17, 2018

5. Government Finance Officers Association: Letter from Emily S. Brock, Director, Federal Liaison Center, dated September 19, 2018 

6. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated September 18, 2018

7. National Federation of Municipal Analysts: Letter from Julie Egan, NFMA Industry Practices and Procedures Chair, and Lisa Washburn, NFMA Industry Practices and Procedures Co-Chair, dated September 17, 2018

8. Office of the Investor Advocate, U.S. Securities and Exchange Commission: Letter from Rick A. Fleming, Investor Advocate, dated September 17, 2018

9. Public Resources Advisory Group: Letter from Marianne F. Edmonds dated September 18, 2018

10. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated September 17, 2018

All Comments to Notice 2018-14

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated July 27, 2018

2. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated July 27, 2018

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated July 26, 2018

All Comments to Notice 2018-10

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated August 6, 2018

2. Government Finance Officers Association: Letter from Emily S. Brock, Director, Federal Liaison Center, dated August 6, 2018

3. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated August 6, 2018

4. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated August 6, 2018

5. State of Florida, Division of Bond Finance: Letter from J. Ben Watkins III, Director, dated August 8, 2018

All Comments to Notice 2018-09

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated July 16, 2018

2. Financial Services Institute: Letter from Robin Traxler, Vice President, Regulatory Affairs and Associate General Counsel, dated July 16, 2018

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated July 16, 2018

All Comments to Notice 2018-03

1. Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated April 20, 2018

2. cfX Incorporated: Letter from Benjamin Madorsky, Chief Compliance Officer, dated April 16, 2018

3. Kensington Capital Advisors: Email from Kim Wyatt dated February 22, 2018

4. National Association of Health and Educational Facilities Finance Authorities: Letter from Charles A. Samuels, Counsel for NAHEFFA, dated April 16, 2018

5. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated April 16, 2018

6. PFM Financial Advisors LLC: Letter from Catherine Humphrey-Bennett, Municipal Advisory Compliance Officer, dated April 16, 2018

7. Piper Jaffray & Co.: Letter from Frank Fairman, Managing Director, Head of Public Finance Services, dated April 16, 2018

8. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated April 16, 2018

1. Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated February 9, 2018