February 10, 2011
SEC,
Please be reminded that the proposed regulations would effect volunteers(not elected ex officio) that serve as board members for municipal entities or philanthropy board of directors. Whether elected or appointed, are typically governed by internal documentation that include safeguards for qualifications, disqualifications, duties, responsibilities, removal, recall, code of conduct and code of ethics, among other things. If the proposed rules become final, appointed board members of municipal entities would be subject to (i) registration with the SEC and yet to be determined MSRB rules, regulations and examination requirements, (ii) a heightened fiduciary duty with respect to any municipal entity for whom they act as a municipal advisor and (iii) compliance with additional federal regulations. Violators may be held civilly and criminally liable. Not to mention the current MSRB charges of $600 for initial and annual registration fees for advisers. These volunteers who currently donate a significant amount of their personal time to contribute to these entities and boards do not need additional regulation and expense to serve their communities.
Regards,
Steve Rochelle
Insurance Alliance
A Marsh & McLennan Agency LLC company