February 28, 2011
I support the proposed SEC rule (34-63576) that defines municipal advisors as those persons providing advice to municipal entities about issuing municipal securities, swap transactions and/or investment strategies under the Dodd-Frank registration, disclosure, and other requirements.
Registration and disclosure requirements should be required of all appointed board and committee members such, as finance committees, prudential committees, trust commissions (trust fund commissions/boards, cemetery commissions/boards, library commissions/trustees) who are appointed by local political whim.
Appointees to such committees, commissions, and boards can make advisory decisions based on political pressure and not sound fiduciary responsibility.
Requiring registration and disclosure will insure that local statutory finance advisors, whether appointed by local bylaw, home rule petition/legislative act, or state law, should be required to register and disclose their background that substantiates an individuals ability to recommend financial advice and/or action for budget recommendations, investment advice/recommendation, debt allocation, or borrowing recommendations as well as disclose any involvement with banking, investing, or other financial institution or relationships.