February 15, 2011
I oppose the treatment of appointed board members as being defined as municipal financial advisors under SEC Rule 34-63576 under the Dodd-Frank act.
The things to remember are as follows:
1. A state or local government governing body, comprised of appointed members, can not serve as an advisor to itself.
2. All members serving on a governing body should be exempt from the municipal financial advisor definition, whether appointed, elected or an employee.
3. Appointed members for govening bodies, especially at the local level, are typically citizen volunteers who are interested in serving the public good, and often have expertise that is critical to the effective functioning of the governing body. Having the federal government impose requirements on appointed and local governing board members could deter good citizens from participating on these boards.
I work at a Housing Autority, and having our commissioners being classified as a financial advisor as outlined in the proposed rule is detrimental to the board members and to the agency.
Director of Finance and Administration
Tacoma Housing Authority