February 21, 2011
Tax-exempt hospitals and health systems depend on citizen volunteers to serve in the capacity of board members. In their role on the hospital boards, members do not provide any financial advice to municipalities on the issuance of financial products. Likewise, key employees of obligated hospital and health systems do not provide financial advice to the municipalities. Requiring registration of board members and key employees as "financial advisors" under the proposed rule may severely limit the ability of tax-exempt hospitals and health systems in attracting capable board members and employees.
I urge the SEC to exclude board members and key employees of tax-exempt entities from the definition of "municipal advisor" in the Final Rule.