February 16, 2011
The City of Plymouth, MN Housing and Redevelopment Authority (HRA) currently operates programs for blighted property redevelopment and affordable housing. The HRA Board consists of five members, one currently is an elected official (City Council) and the others are citizens of Plymouth. No Board member is compensated for the work they do. Programs that the HRA Board oversees are: Tax Increment Financing, Section 8, First Time Home Buyer, Low Income Housing, social service agency assistance and senior housing management. The definition opined by the SEC would dramatically and negatively affect the programs that the City of Plymouth and Plymouth HRA offer to low income and disadvantaged residents. I submit the following points to consider:
A state or local government governing board, comprised of appointed members, cannot serve as an advisor to itself
All members serving on a governing body should be exempt from the municipal financial advisor definition, whether appointed, elected or an employee and,
Appointed members of governing bodies, especially at the local level, are typically citizen volunteers who are interested in serving for the public good, and often have special expertise that is critical to the effective functioning of the governing body. Having the federal government impose requirements on appointed state and local governing board members could deter citizens from participating on these boards.