October 18, 2022

Dear Leader Schumer, Minority Leader McConnell, Chairman Reed, and Ranking Member Inhofe:

The organizations listed above, representing nearly all sectors of the municipal securities market (issuers,
investors, underwriters, counsel and advisors) are writing to express our objections to the Financial Data
Transparency Act (FDTA). While all our organizations strongly support financial transparency and robust
financial reporting in the municipal securities sector, as it is currently written, we oppose inclusion of
Section 203 in S. 4295.

Section 203 of the FDTA does not adequately address the numerous inherent financial complexities
between the various types of governmental entities in the public sector. In contrast, the private sector
parameters that are both already in place and also addressed in the FDTA cannot easily, readily or
similarly be applied in the public sector. The efforts to standardize financial data in the public sector not
only would ironically create a lack of transparency, but also would likely create volatility and disruption
in the municipal marketplace, which would burden and add greater costs to governments and
governmental entities.

While there is merit in the development and acceptance of machine readable documents in our sector, to
address the uniqueness of our market in total, and the over 40,000 governments, governmental entities
and nonprofits that would individually be impacted by the mandate, additional time, study as well as
greater attention and care is needed than is currently included in section 203.

It is imperative for the legislation to have longer time to identify appropriate structure, development and
phase in periods. This is best accomplished by a concerted and committed effort to involve all municipal
market participants – especially issuers of municipal securities and those who will ultimately use the data,
to be effective. We also recommend the adoption of a small voluntary pilot program as a first step to
address the challenges that such a significant change in governmental financial reporting would
encompass. This would allow the glitches of a new system to be ironed out so that the standards can be
applied correctly, efficiently and transparently to all governments and governmental entities.

We call on congressional leaders to work with our industry to develop an appropriate timeline and plan
for implementation, to address concerns related to the regulatory regime in our sector that is different than
the corporate sector and to start the process with a pilot program before mandating new standards on the
entire public sector.

We welcome the opportunity to discuss these concerns and work with you as the FDTA is considered this
117th Congress and we look forward to collaborating with you on any other matters of mutual concern of
the municipal marketplace.

Sincerely,

• Government Finance Officers Association, Emily Swenson Brock
• National Association of Bond Lawyers, Brian Egan
• National Assn of Health and Educational Financing Facilities Authorities, Chuck Samuels
• National Association of Municipal Advisors, Susan Gaffney
• State Debt Management Network, Dillon Gibbons
• National Federation of Municipal Analysts, Lisa Good
• American Public Power Association, John Godfrey
• Bond Dealers of America, Michael Decker