Subject: File No. S7-45-10
From: Cynthia Marek
Affiliation: V.P. Financial Affairs Higher Education

February 17, 2011

It has come to our attention that our employees and board of trustees may be subject to SEC regulation as "municipal advisors" when acting for, or advising the institution in a municiple revenue bond transaction or related investing activity. We urge the SEC to exclude members of the governing boards and employees of private, nonprofit college and universities from the definition of "municiple advisor" for reasons described by others (including the National Association of Health and Higher Educational Facilities Authorities). We believe state laws, our corporate bylaws and good governance practices are already in place to guide standards of conduct and address possible conflicts of interest.