February 25, 2016
The National Federation of Municipal Analysts (NFMA) appreciates the opportunity to respond to the Securities and Exchange Commission request for comments regarding proposed changes to Rule A-3 in SR-MSRB-2016-1. The NFMA is a not-for-profit association with nearly 1,400 members throughout the United States, and is primarily a volunteer-run organization. The NFMAs goals are to promote professionalism in municipal credit analysis, to conduct educational programs for members and other interested parties, to promote better disclosure by issuers and to advocate for good practices in the municipal bond marketplace. The NFMA seeks to educate its members, and by extension, the public at large, about municipal bonds. Annual conferences are open to anyone wishing to attend and our Recommended Best Practices in Disclosure and White Papers are available via our website, www.nfma.org.
The NFMA's membership is diverse, with individuals who work for mutual funds, trust banks, wealth management companies, rating agencies, credit providers, independent research groups and broker-dealer firms. NFMA membership is open to all analysts because we believe we can learn from one another and share a common interest in promoting good practices in the marketplace. The NFMA is not an industry interest group and does no political lobbying. NFMA board members, although generally employed within the financial services industry, do not represent their firms while they serve.
The NFMA supports the proposed amendments to Rule A-3 regarding MSRB Board membership as contained in SR-MSRB-2016-1. We believe that the extension of Board terms from three to four years strikes an appropriate balance between gaining necessary continuity on the Board without overburdening its members with significantly longer terms. Overall, with less turnover, we feel that Board members will be better able to make considered judgments on issues that have been under discussion for multiple years. We also believe that the two term limit is appropriate for this Board in order to encourage broader participation from both industry participants and public representatives.
Thank you very much for the opportunity to comment on this proposal.