Subject: S7-19-99, Contributions to Advisors Author: Paul McDonnell at Internet Date: 8/23/99 4:49 PM As a former investment banker and a current elected official familiar with G-37 I find the Commission's latest foray in municipal affairs to be an unwarranted intrusion. The case for proceeding is not based upon any demonstration that contributions in this area have led to widespread corruption. Yes, the Blount decision did not require such evidence, but it any other area of endeavor demonstration of a problem would be required prior to the imposition of a legislative or regulatory remedy. At the same time, this is an issue that is tangential, at best, to the mission of the Commission. Given the limited resources available to the Commission, its efforts would be best spent in those areas affecting the markets as a whole, or in those areas where there are clear patterns of abuse. As noted in the Commission's report a number of states have already taken steps to address perceived abuses. I would suggest that working with state officials would be appropriate prior to taking this type of action.