Subject: File No. S7-45-10
From: Michael A Swift
Affiliation: Shelby County, Tennessee Government

January 28, 2011

We agree that registration for municipal advisors needs to be tightened but ask that you be very careful to not have unintended consequences. It is very important that citizens rather than government officials and employees be board members for pension plans, industrial development boards and other such entities. Having most or all government officials and employees on these boards may result in decisions for political or personal benefit rather than the good of the community.

In recognition that these boards do make significant financial decisions, we would recommend that for governmental entities that have a paid or volunteer registered municipal financial advisor, the board members of pension plans, industiral development boards and other governmental entities be exempt from registration for municial advisors. Of course, the registered municipal financial officer needs to be required to maintain independence with respect to all financial actions.