Subject: File No. S7-45-10
From: John J Gallagher, Jr
Affiliation: Executive Director Policemen's Annuity and Benefit Fund of Chicago

February 22, 2011

Assistant Director Haines:

I am the Executive Director for the Retirement Board of the Policemen's Annuity and Benefit Fund of Chicago, a public employee retirement system here in the great City of Chicago. I would like to communicate to you my opposition to Proposed Rule 34-63576. The Board and staff of the Fund oppose this rule because

1. A local government pension fund like PABF of Chicago is composed of elected and appointed members and the trustees cannot act as an Advisor(s) to itself.
2. All trustees serving on the board should be exempt from the municipal financial advisor definition. I believe the reach of the Doff-Frank Act was not intended to cover these types of positions.
3. The members of the board are active or retired officers as well as appointed citizens that serve without compensation and offer the benefit of their expertise to the board and I fear federally imposed registration requirements could serve to deter citizens from serving on the board, denying the board access to talented individuals that can be of great service to a board such as this.

Thank you for your consideration.


John J. Gallagher Jr.
Executive Director
Policemen's Annuity and Benefit Fund of Chicago
221 North LaSalle St. Ste. 1626
Chicago, IL. 60601

Office (312)744-3891
Fax (312)726-3216