Mike Goodwin, Division Director
Jared Waters, Program Manager
Bureau of the Fiscal Service
P.O. Box 396
Parkersburg, WV 26106-1328

Mr. Goodwin and Mr. Waters:

The National Association of Bond Lawyers (“NABL”) respectfully submits the enclosed comments with respect to the proposed regulations pertaining to the State and Local Government Series (“SLGS”) securities program (Docket ID No. FISCAL-2022-0002).  

NABL appreciates the significant work by the Bureau of the Fiscal Service (“BFS”) and the U.S. Department of Treasury in preparing the Notice of Proposed Rulemaking addressing certain perceived abuses of the SLGS program.  While NABL is not presently aware of any significant abuses of the program, any such abuses have the effect of reducing the effectiveness of the program by issuers seeking to comply with applicable federal tax laws.  As such, NABL whole-heartedly supports BFS’s desire to prevent abuse of the SLGS program. 

NABL is a nonprofit organization and specialty bar association of approximately 2,500 lawyers whose purposes include, among other things, providing advice and comment at the federal, state, and local levels with respect to legislation affecting state and municipal obligations.  NABL believes that participating in the guidance process supports clarification of, and facilitates compliance with, tax laws and regulations.  Accordingly, NABL members would welcome the opportunity to discuss these recommendations to achieve the goal of reducing abuses of the program while permitting additional uses of the program by well-intentioned issuers of tax-advantaged debt.  

Thank you in advance for your time and attention here.

Best,

Joseph (Jodie) E. Smith
President
National Association of Bond Lawyers (NABL)