April 4, 2010
I submit this comment in support of the MSRB proposal (File No. SR-MSRB-2010-02) to expand transparency of variable rate securities.
I hold small positions in two NY municipal ARS securities in my Fidelity Investments brokerage account. Over the past year, I have made countless requests to Fidelity for much of the same information that would be reported under this proposal. Fidelity has been unable to provide any help. In fact, numerous times I have been informed by traders and managers at Fidelity that they have essentially no information about the auction process for the securities I hold. For example, they have been unable to provide me any information about how, in the event of a partly successful auction, sell orders will be allocated. In fact, Fidelity cannot even confirm whether the ARS program dealer has acted on the sell orders Fidelity submits. Further, despite several written complaints, Fidelity continues to post erroneous information (erroneous "next anticipated rate" data) relating to the auctions for these securities on its web site.
This complete lack of transparency creates the opportunity for manipulation and unfair dealing and has no place in a legitimate securities market. I fully support the changes proposed by the MSRB to address these issues.
107 Cleveland Dr
Centerport, NY 11721