Steuben Lakes Regional
8119 W 150 N
Angola IN 46703
February 22, 2011
U.S. Security and Exchange Commission
100 F Street, NE
Washington DC 20549-1090
RE: File Number S7-45-10
To Whom It May Concern:
The U.S. Security and Exchange Commission recently issued proposed rules that would require appointed board members of municipal entities to register with both the SEC and the Municipal Securities Rulemaking Board (MSRB) if they advise on the issuance of municipal securities. Our District believes these rules would have a negative impact on the ability of state and local officials to find volunteers willing to serve on the boards of bond issuing municipalities.
Our Board for one is appointed by the elected township trustees and our board members receive a stipend of $50 per meeting. It would be very difficult to justify their service to the public if they are subject to SEC regulation of their activities. Our Board employs a professional firm that specializes in bonding matters.
We do have certain procedures required by the Indiana Code before bonds are issued that include but not limited to such things as passing a bond ordinance which requires to be done at a public meeting(s), and having a review by our legal counsel as well as Ice Miller bond legal counsel. All of this information is available through the access to public records.
We ask that you consider expanding the exclusion for local government officials to include appointed and/or volunteer public officials of municipal entities from the requirement to register as "municipal advisors" by including them in the definition of "municipal employees"
Thank you for your time in this matter.
Tim Frederick, Superintendent
Steuben Lakes Regional Waste District
8119 W 150 N
Angola, IN 46703