February 16, 2011
I wish to object to provisions of the proposed rule that suggest that any person appointed to a governing board may be deemed to be a Municipal Advisor and subject individually to registration and regulation. If approved, the proposed rule will have a negative effect on the ability to find qualified, experienced volunteers that are willing to serve on governing boards of bond-issuing authorities. These volunteers are often appointed by elected officials and subject to the same open meetings laws, public record laws, and code of ethics as entities governed by elected officials. The proposed rules confuse appointed officials roles, suggesting that appointed board members, who should be among the intended beneficiaries of municipal advisor regulation, are "municipal advisors" themselves. I would also second guess myself serving on the Ozaukee County Economic Development Board, as I have for the past 12 years.
Thank you for listening.