Subject: File No. S7-45-10
From: Doug Robinson
Affiliation: Finance Director, City of Lenexa, Kansas

February 18, 2011

As Finance Director for the City of Lenexa, I am writing to encourage you to exempt appointed members of a governing body of a municipal entity from the definition of "municipal advisor".

If approved as currently proposed, the rules will make it much more difficult to find qualified, experienced volunteers that are willing to serve on governing boards of bond-issuing authorities. These volunteers are usually appointed by elected officials and are subject to the same open meetings laws, public record laws, and code of ethics as entities governed by elected officials.

In summary, these volunteers are not providing financial advice to municipal entities and therefore, should not be included in the definition of "municipal advisor".