Subject: File No. S7-45-10
From: Richard R Vosburg
Affiliation: Chartered Financial Analyst

January 24, 2011

I believe the definition of Municipal Advisor as proposed is overly broad and produces the unintended result of discouraging volunteer citizen participation in local commissions.
I have served on the Germantown, Tennessee, Retirement Plan Administration Commission and Industrial Development Board for several years. All citizen members are uncompensated volunteers who must abide by a city code of ethics addressing possible conflicts of interest. I believe the local city is the appropriate venue to oversee local commission appointee behavior. An exemption to the registration requirement for uncompensated volunteers would be a satisfactory resolution.
I am a retired financial analyst. The registration fees and procedures are not trivial to volunteers and would cause my resignation from both commissions.
If the citizen members of the Retirement Plan Administration Commission resign the city retirement plan will be administered by city employees who are plan participants without taxpayer citizen involvement. The Industrial Development Board is one of the primary forces for economic development in our community. With no members the Board will probably disband.
I request you consideration of an exemption from the definition of Municipal Advisor for uncompensated volunteer citizen appointments to city boards and commissions.