Subject: File No. S7-45-10
From: Kari Roberts
Affiliation: President/CCO

February 15, 2011

In regards to the proposal requiring a bank or its employees to register as a "municipal advisor":

Our community bank accepts deposits from local government entities, such as the county, city, and school. We do not offer "advice" on how these entities place their deposits. However, with the term "advice" undefined, one could assume that we would now fall under SEC supervision. This would force the bank to incur the cost and red tape of registering, placing an unfair burden on any bank wanting to accept municipal deposits.

These costs will either force us to NOT accept municipal deposits, or would force us to impose a fee. Neither one of these options will benefit the county or city.

Kari Roberts
ACB Bank, Cherokee