Subject: File No. S7-45-10
From: Stevan Gorcester
Affiliation: Director of State and Federal Relations, Association of Washington Cities

February 22, 2011

The Association of Washington Cities represents all 281 cities in Washington State. We are very concerned about the inclusion of appointed members in the definition of municipal advisors. Appointed board members should be categorized no differently than elected board members and employees of a municipal government. Many of our appointed members are not compensated or are compensated very little. Paying fees and submitting to registration requirements would likely discourage our much needed citizen volunteers from participating.

Please exclude appointed members from the definition of municipal advisor.