John J. Cross, III

Associate Tax Legislative Counsel
Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

RE: Reissuance Concerns Related to Certain Private Purchases of Multimodal Tax-Exempt Obligations

Dear Mr. Cross:

The National Association of Bond Lawyers (“NABL”) respectfully submits the attached memorandum discussing how reissuance principles, including those of Notice 2008-41, might be applied in the context of multimodal, or other interest rate reset, tax-exempt municipal obligations that are privately purchased rather than publicly offered. In view of the increasing participation of banks as purchasers in the municipal finance market, NABL believes that reissuance guidance to address the instruments used in these financings would be very helpful to market participants. In that light, after your consideration of the attached paper, members of the NABL Board and the NABL Tax Committee would like to engage you, and officials in the IRS Office of Chief Counsel, in a dialogue on these issues.

NABL exists to promote the integrity of the municipal market by advancing the understanding of and compliance with the law affecting public finance. We respectfully provide this submission in furtherance of that mission. A list of the NABL members who participated in this project is attached as Appendix B.

Sincerely,

Kristin H. R. Franceschi

President
National Association of Bond Lawyers (NABL)