Subject: File No. S7-45-10
From: John D Bell
Affiliation: General Counsel

March 15, 2011

The proposal to regulate volunteer appointed Board members of units of local government as municipal financial advisors lacks any basis in the furtherance of the aims of the Dodd-Frank Act. Appointed Board members of units of local government form a vital part of the administration of local housing, transportation, medical service, fire fighting and other public safety services. They are appointed by elected officials who directly respond to public oversight.

Nothing in the recent financial meltdown that is the subject of the Dodd-Frank bill even remotely involves the activities of these public servants. To argue that their simple decision-making process as public officials is in some way analagous to a "municipal financial advisor" in any kind of regulatory sense is unfounded.