ARLINGTON, Va. – The following is a statement from Craig P. Hoffman, General Counsel and Director of Regulatory Affairs of The American Society of Pension Professionals & Actuaries (ASPPA) in response to the request for comment from the U.S. Securities and Exchange Commission (SEC) on Release No. 34-63576 for Registration of Municipal Advisors.

"ASPPA and the National Tax Sheltered Accounts Association (NTSAA) express concern with regard to how the application of proposed new rules 15Ba1-1 through 15Ba1-7 under the Securities Exchange Act of 1934, will impact retirement plan professionals who work with governmental sponsored retirement plans.

We believe that the Dodd-Frank Wall Street Reform and Consumer Protection Act was not intended to extend the municipal advisor registration requirements to those who work with governmental retirement and savings plans. This is particularly true for governmental retirement savings plans funded exclusively with employee contributions. Similarly, providers of advice and information to the participants in governmental retirement and savings plans should not be subject to registration as municipal advisors.