February 15, 2011
I am writing to oppose the SEC's proposed definition of municipal financial advisor (SEC Rule 34-63576). In its present form, the proposed rule would include appointed members of the City of Norwalk's pension board in such definition.
The City's of Norwalk Pension Board is comprise of local citizen volunteers who are interested in serving their community and the public good. Several members of the board have special expertise which is crucial to the effective functioning of this board. Having the federal government impose requirements on appointed board members will deter citizens from volunteering for this board, and will hinder our ability to make sound, professional investment decisions.
A state or local government governing board, comprised of appointed members, can not serve as an advisor to itself. All members serving on a governing body should be exempt from the municipal financial advisor definition, whether appointed, elected, or an employee.