Subject: File No. S7-45-10
From: Christopher E Halvorson
Affiliation: Investment Officer

February 22, 2011

I am on the staff of the Idaho Endowment Fund Investment Board (the EFIB). I am writing to express my concern about the proposal to require appointed board members of public boards to register as Municipal Advisors.

Idaho law imposes fiduciary standards on EFIB members and the board is mindful of those duties as it oversees the funds. In addition, the Idaho laws concerning conflicts of interest, gifts and gratuities, open meetings, and public records apply to EFIB members.

Appointed members of public boards are volunteers interested in serving their communities who receive no financial benefit from their service. Many public board members are selected because of their knowledge of the community or their expertise concerning the agency or government entity that benefits from the funds overseen by the public board. The effect of requiring these board members to register as Municipal Advisors will be to limit the pool of volunteers to those already registered as Municipal Advisors or registered under similar registration provisions. Public boards will loose the valuable insight provided by everyday citizens.

I respectfully request that the Commission clarify that all members of public boards are excluded from the definition of a Municipal Advisor. Thank you for the opportunity to comment.