Subject: File No. S7-45-10
From: MARY M DATKA, CPA, CPM
Affiliation: DIRECTOR OF FINANCE MANAGERIAL SERVICES

February 15, 2011

Oppose requiring appointed board members of a governing body to register with the SEC as investment advisors.

1. Governing Board is elected to 3 year terms. They are basically volunteers. Requiring them to register may deter applicants.
2. We hire financial advisors to guide and recommend. Decisions are made from several ideas. We do not advise ourselves.
3. We adher to State Statute on the types of investments allowed. We limit our choices to CDs, money markets and the State of Wisconsin Investment Pool which invests in government securities.
4. The appointed Treasurer does not function as an investment advisor, but follows the State Statute and Village investment policy which sets the goals of 1. safety, 2. liquidity and lastly 3. rate of return.