Subject: SR-MSRB-2009-10

September 4, 2009

I support the GFOA's decision to oppose the MSRB's proposal to add a field indicating if an issuer will voluntarily submit its annual financial information within 120 days of the end of its fiscal year.

As an issuer who is fortunate enough to deal with a large accounting firm with expertise in the area of government accounting and auditing, we do all we can to get our financial information submitted in the existing required timeframe. We, along with our auditors work diligently to get the financial information as accurate and complete as possible and by suggesting this "voluntary" submission we, like other governmental entities would aspire to comply, possibly at the expense of providing the highest quality financial information. Governmental audits have become increasingly rigorous and in order to get them accurate, an extended timeframe is required.

Thank you for your consideration of this opinion.

Eileen Bradley
Assistant Director of Finance
Township of Lower Merion