Subject: File No. S7-45-10
From: Chris Chronis
Affiliation: CFO, Sedgwick County Kansas

February 17, 2011

I object to the part of this proposed rule that would require any person appointed to a governing board to register as a Municipal Advisor and comply with the regulations applicable to such positions.

Sedgwick County has created a Public Building Commission to finance certain public facilities through the issuance of lease-revenue bonds. The financed facilities are owned by the PBC and leased to the county to support its mission. The bonds are secured by rental payments made to the PBC by the county. The PBC governing board consists of unpaid local residents who are appointed by the Sedgwick County Board of County Commissioners. They are subject to the same requirements of transparency in their decision-making as the elected body that appoints them: they may meet only in pre-announced public sessions their actions must be recorded and virtually all documents they see in their official capacity are subject to disclosure to any citizen on request. They provide no advice and have no authority to engage in project finance other than for projects explicitly requested by the elected County Commission.

Requiring registration and regulation of the citizens volunteering to serve as PBC board members would cause many, if not most, citizens to decline appointment to board slots. This in turn would adversely affect the county's ability to undertake and finance essential public projects.