February 17, 2011
I am opposing the proposed SEC rule (SEC Rule 34-64-63576) of appointed members of governmental bodies as financial advisors. As a volunteer citizen serving on the City of Portsmouth, Virginia Supplement Retirement Board, I feel that all members serving on a governing body should be exempt from the municipal financial advisor definition, whether appointed, elected or an employee. Collectively, as board members we receive the advice of a qualified, licensed, and professional financial advisor. We do not act in any capacity as a financial advisor toward the inactive employees of the City of Portsmouth however, I feel that it is our fiduciary duty to be educated and knowledgeable in the investment management and to understand the information and reports disclosed to us. If you were to proposed a SEC rule, the rule should be comprise of basic education of investments management for appointed member of governmental bodies in which, the investment education should not include taking a series license exam. The incorporation of the investment education should be handled by state and local government.