Subject: File No. S7-19-10
From: Brad R Jacobsen

September 7, 2010

Will small issuers such as individual charter schools (that are deemed public schools by the state with individual charters) be included in the definition of "Municipal Entity?"

Many charter schools raise funds through municipal bonds for small amounts (just enough to build their schools). The people who advise these charter schools may be members of the board or community volunteering their time or small financial advisors familiar with financing. To require such persons to register (assuming more than mere registration in the future would be required) would be onerous and raise the cost to these cash-strapped schools trying to raise money.

Will there be some type of "small-financing" or "small-municipal entity" exemption?

Thank you.