WASHINGTON The Government Finance Officers Association said yesterday an MSRB proposal that would bar dealers from passing on to issuers fees paid to the board may be hard to enforce and easy to circumvent.

"While we support the intent of the proposed rule change, we are concerned that the change might be largely 'cosmetic' when put into effect," said Catherine L. Spain, the association's chief lobbyist, in a Sept. 21 comment letter to the Municipal Securities Rulemaking Board.

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