Subject: File No. S7-45-10
From: David G. Ellis
Affiliation: Lewis & Clark College

June 5, 2012

Dear Secretary Murphy:

I write to comment on the proposal that would require all 32 members of the Governing Board of our private college, as well as several of the senior staff, to register as "municipal advisors". We agree with the points made by the Association of Governing Boards ("AGB") in their letter of February 15, 2011 and with the suggested code language proposed by AGB in its March 8, 2012 letter to the Secretary. College Trustees are decision makers regarding policies and other important matters at the nations college's and universities. They serve as governing bodies, make decisions for the institutions they serve, not as advisors to those institutions. Please add our comment of support for the AGB proposed course of action, and in opposition to a rule that would require the members of the Lewis & Clark Board to register as municipal advisors.

Thank you for your consideration.

Best Regards

David G. Ellis
VP, Secretary and General Counsel
Lewis & Clark College