Subject: File No. S7-45-10
From: Philip G. Burke
Affiliation: Garland Housing Finance Agency

January 17, 2011

The subject proposed rule would impose on our Garland Housing Finance Board Members (voluntary citizens of the community rendering a public service on a strictly voluntary, non paid basis) an unncessary and burdensome duty to permanently register with the SEC as "Municipal Advisors" and to be held accountable for disclosing, among other things, personal information and employment history, be duty bound to certain "record keeping" requirements, and be liable for civil and/or criminal matters that would be beyond the scope of knowledge of such board members. Our board members do not purport to be or hold themselves out to be knowledgeable, credentialed financial and legal advisors. They rely strictly upon the advice and counsel of widely recognized experienced, knowledgable, and credentialed financial and legal professionals engaged by the board to carry out the financial strategies and transactions of the housing finance corporation.

Philip G. Burke
Board President
Garland Housing Finance Agency
(Garland, Texas)