February 15, 2011
I would like to voice my strong opposition to the proposed rule by the SEC to require volunteer board members of a municipal board to register as “municipal financial advisors”. As the General Manager for a Water Commission in central Illinois with an 8 member board I see huge problems with the proposed rule. I feel this current views of the SEC are flawed on a few different points. These volunteers are appointed by the mayors of the towns they represent, they are considered employees by the IRS, the State of Illinois and others. While their pay is limited to $2,000 per year by State Statute, our board self limits their pay to $1,000 per year, their time invested in providing safe drinking water to their communities is huge. They do not provide advice on finances but are quite often seekers of advice. They are held accountable to directly to their respective city councils, failure to adequately perform their assigned task could result in not being reappointed , similar to not being reelected.
The expense of the registration and possible continuing education would be a burden on the rate payers of the water system, while providing no real service to them. Requiring any type of testing to certify these board members would also be a burden on the board member, not to even consider what authority would provide testing, and what the end result would be for a board member that was unable to successfully pass such an exam. The most daunting part of this rule is the effect it would have on the volunteer pool that serves on this Water Commission board and the other 23 such boards within the state of Illinois alone. The thought of the requirement to register with the federal government as an advisor on a subject they have little knowledge of, or need of for that matter, would scare away members of the general public that have successfully served this Water Commission since 1967.
Otter Lake Water Commission