February 15, 2011
Along with other members of the state and local government groups, I strongly oppose the SEC's proposal to define appointed board members of a government body such as a public pension board as financial advisors under the Dodd-Frank Act.
Oppositon is for the following reasons:
1. A state or local government governing board, comprised of appointed members, can not serve as an advisor to itself.
2. All members serving on a governing body should be exempt from the municipal financial advisor definition, whether appointed, elected or an employee.
3. Appointed members of governing bodies, especially at the local level, are typically citizen volunteers who are interested in serving for the public good, and often have special expertise that is critical to the effective functioning of the governing body. Having the federal government impose requirements on appointed state and local governing board members could deter citizens from participating on these boards.
Thank you for your consideration in this matter.