Subject: File No. S7-45-10
From: Dr. Richard J. Sherry
Affiliation: Bethel University

June 28, 2012

Elizabeth M. Murphy
Securities & Exchange Commission
100 F Street, N.E.
Washington, DC 20549-1090

Dear Secretary Murphy:

Bethel University respectfully concurs with the position of the Association of Governing Boards in its letter to the Securities and Exchange Commission of March 8, 2012. The Commission's proposed language regarding the registration of "municipal advisors" appears to require that university staff members and trustees must register, though acting within the proper scope of their employment. This novel perspective may have unfortunate consequences both for staff members and trustees. We request that you consider carefully and adopt the replacement language proposed by the Association of Governing Boards.

Dr. Richard J. Sherry, Executive Assistant to the President
Bethel University, 3900 Bethel Drive, St. Paul, MN 55112