February 19, 2011
Assistant Director Haines:
I am the President of the Mundelein (IL.) Firefighter's Pension Fund and am writing on behalf of the Board of Trustees. We are opposed to the Proposed Rule 34-63576 for the following reasons:
1. A local government pension fund like ours which is comprised of appointed members cannot serve as an advisor to itself.
2. Members serving on these local boards should be exempt from the municipal financial advisor definition, whether appointed, elected or an employee. The reach of the Dodd-Frank Act was not intended to cover these types of positions.
3. The members of the Mundelein Firefighter's Pension Board are firefighter members or appointed citizens who serve with no compensation and use their expertise to benefit the pension fund. Federally imposed registration requirements could serve to deter citizens from serving on boards such as the pension board.
Thank you for your consideration.
Carl LoMastro