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From: Pearlman, David April 24, 2006 VIA E-MAIL
Jonathan G. Katz, Secretary Re: SR-MSRB-2006-3 Dear Mr. Katz: I am writing to you today on behalf of the College Savings Foundation ("CSF"). CSF is a 501(c)(6) organization dedicated to the advancement of 529 college savings programs. CSF's mission is to help American families achieve their education savings goals by working with public policy makers, media representatives and financial services industry executives in support of education savings programs. CSF's members include many of the country's leading financial services firms, and collectively manage more than $30 billion in savings-type qualified tuition programs, representing nearly one-half of the dollars in such programs. CSF also includes associate members that are governmental and non-profit agencies and individuals who support CSF and its mission. CSF serves the education savings industry as a central repository of information and an expert resource for its members and for representatives of state and federal government, institutions of higher education and other related organizations and associations. The primary focus of CSF is building public awareness of and providing public policy support for 529 plans - an increasingly vital college-savings vehicle. This letter is to respond to proposed interpretative guidance (the “proposed interpretation”) submitted by the Municipal Securities Rulemaking Board (the “MSRB”) relating to customer protection obligations of brokers, dealers, and municipal securities dealers marketing 529 college savings plans. CSF strongly supports the proposed interpretation and wants to commend the MSRB for the thoughtful consideration it gave to comments provided by industry commentators in response to MSRB Notice 2005-28. The MSRB has also demonstrated a wonderful willingness to work with industry members to shape the regulatory landscape for 529 college savings plans. CSF agrees that the proposed interpretation will strengthen and clarify 529 dealers’ customer protection obligations as well as improve current and future disclosure practices and availability in the marketplace. CSF will work with its members, the MSRB, and other 529 trade organizations to continue to maximize transparency in the industry and support the objectives of the proposed interpretation. Again, we appreciate the opportunity to express our support for the proposed interpretation submitted by the MSRB. If we can be of further assistance, please do not hesitate to call me at 817-474-8298 or send me an email at david.pearlman@fmr.com. Sincerely, /s/
David J. Pearlman |