October 20, 2015
Urging the Internal Revenue Service (IRS): to exempt competitive sales of municipal debt from
any issue price rule; to provide specific guidance on acceptable documentation to be used in
determining market changes and acceptable variances in the offering price under the proposed
alternative method of determining issue price; to establish an efficient process that can quickly
and definitively be executed so as not to hinder the proper sizing of an escrow account on the bond
sale date; and to eliminate enforcement responsibilities for the municipal bond issuer.