Subject: File No. SR-MSRB-2012-06
From: Shelly Frank

July 10, 2012

The firm I have been buying municipal bonds from will no longer send me the scale on new municipal issues that they bring to market. The firm sites MSRB rules for this change. As a retail investor, I am now at a disadvantage from institutional clients that do see the full scale. Municipal bond issuers want retail investors to have the first option to buy new issues, but if we can't see the scale we are not fully able to evaluate the yield curve and relative yields among different new issues. What happened to the transparency and level playing field that MSRB mandated? The institutions are now able to buy the new issues for inventory, mark them up a few points and sell them to retail buyers at a premium over the original issue price. We need to see the scale just like the institutions do.

You have indicated that it's important for pricing information with regard to new issues that have already been priced to be made available. It is even more important for muni bond investors to see the scales before the pricing is final. This gives all investors the opportunity to place orders at the original issue price.
My broker informs me that his firm is quoting MSRB rules as the very reason that he is no longer allowed to e-mail scales to his customers. They say it is as a result of your rules.

It's good that, as an individual investor, I can see the pricing after a deal is priced, but I will feel taken advantage of when the price of a particular bond that is being offered to me is significantly higher than the issue price when I should have had an opportunity to buy this bond on the offering.

Please incorporate into your rules a manner in which retail customers can see the scales before the price is final so they have an equal chance to evaluate the issue at the original issue price. The brokerage firms I deal with do not seem interested in finding a solution, perhaps because the commissions are greater in the secondary bond market. The situation now is not fair to the municipal bond investor. This abuse of the retail side of the muni market requires a regulator to dictate a rule in the interest of fair play, full transparency and a level playing field regarding new issues.

Thank you,