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Notice 2021-18 - Request for Comment
Publication date: | Comment due:
Information for:

Municipal Advisors

Rule Number:

Rule G-17, Rule G-46

All Comments to Notice 2021-18

1. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated March 15, 2022

2. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 15, 2022

3. Third-Party Marketers Association: Letter from Donna DiMaria, Chairman of the Board of Directors and Chair of the 3PM Regulatory Committee, dated March 15, 2022

Notice 2021-17 - Request for Comment
Publication date: | Comment due:
Information for:

Municipal Fund Securities

All Comments to Notice 2021-17

Summary of Responses to the MSRB's Request for Information on ESG Practices in the Municipal Securities Market (August 2022)

1. 1919 Investment Counsel, LLC: Letter from Robert Fisher, Vice President, Credit Analyst - Municipal

2. AGVP Advisory: Email from Dan Aschenbach dated January 18, 2022

3. American Bankers Association: Letter from Justin M. Underwood, Executive Director, ABASA, Vice President, Banking Policy, dated March 8, 2022

4. American Securities Association: Letter from Christopher A. Iacovella, Chief Executive Officer, dated March 8, 2022

5. Anonymous: Email dated February 21, 2022

6. Baker Tilly Municipal Advisors, LLC: Letter from the BTMA Disclosure Leadership Team: Brian Colton, Susan Reed and Alyssa Glaser, dated March 8, 2022

7. Bloomberg L.P.: Letter from Gregory Babyak, Global Head of Regulatory Affairs, dated March 8, 2022

8. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated March 8, 2022

9. Breckinridge Capital Advisors, Inc.: Letter from Adam Stern, Co-Head of Research, dated February 7, 2022

10. Build America Mutual: Letter from Laura Levenstein, Chief Risk Officer, and Michael Stanton, Head of Strategy & Communications, dated March 8, 2022

11. California Green Bond Market Development Committee (CGBMDC): Letter from David Wooley, Cecilia Latapi, and Michael Paparian, Secretariat for CGBMDC, dated March 8, 2022

12. Center for American Progress: Letter from Alexandra Thornton, Senior Director, Tax Policy, and Kevin DeGood, Director, Infrastructure Policy, dated March 8, 2022

13. Ceres and the Ceres Accelerator for Sustainable Capital Markets: Letter from Steven M. Rothstein, Managing Director, and Jim Scott, Senior Advisor, Financial Institutions, dated March 2, 2022

14. City of Detroit: Letter

15. City of New York, Office of the Comptroller: Letter from Marjorie E. Henning, Deputy Comptroller for Public Finance, dated March 7, 2022

16. City of San Diego, Debt Management: Letter from Lakshmi Kommi, Debt Management Director, dated March 9, 2022

17. Climate Resilience Consulting: Email from Joyce Coffee dated December 17, 2021

18. Community Capital Management, LLC: Letter from Julie Egan, Director of Research/Portfolio Manager

19. Consumer Federation of America: Letter from Dylan Bruce, Financial Services Counsel, dated March 14, 2022

20. Disclosure Industry Workgroup: Letter dated March 8, 2022

21. Domini Impact Investments LLC: Letter from Mary Beth Gallagher, Director of Engagement, dated March 8, 2022

22. Goldman Sachs: Letter

23. Government Finance Officers Association: Letter from Emily Swenson Brock, Director, Federal Liaison Center, dated March 8, 2022

24. Intercontinental Exchange, Inc.: Letter from Anthony Belcher, Vice President, Sustainable Finance, dated March 14, 2022

25. Investment Company Institute: Letter from Dorothy Donohue, Deputy General Counsel - Securities Regulation, dated March 8, 2022

26. ISS ESG: Letter from Maximilian Horster, Head of ISS ESG Business, and John McLean, ISS ESG, Muni QualityScore, dated March 8, 2022

27. Kestrel 360, Inc.: Letter from Monica Reid, CEO and Founder, dated March 2022

28. Lansing Board of Water & Light: Email from Heather Shawa, dated March 3, 2022

29. Large Public Power Council: Letter from John Di Stasio, President, dated March 22, 2022

30. Lord Abbett & Co. LLC: Letter from Daniel S. Solender, Partner and Director of Tax Free Fixed Income

31. Ludvigsen, Phillip J.: Letter 

32. MacKay Shields: Letter

33. McIntyre, James: Letter dated March 8, 2022

34. Milken Institute Center for Financial Markets: Letter from Dan Carol, Senior Director, Milken Institute Center for Financial Markets, and Caitlin MacLean, Senior Director, Innovative Finance, Milken Institute, and members of the Milken Institute Public Finance Advisory Council, dated March 8, 2022

35. National Association of Bond Lawyers: Letter from Ann D. Fillingham, President, dated March 7, 2022

36. National Association of College and University Business Officers: Letter from Elizabeth L. Clark, Vice President, Policy and Research, dated March 8, 2022

37. National Association of Health and Educational Facilities Finance Authorities: Letter from Dennis Reilly, President, and Charles Samuels, of Counsel, dated March 7, 2022

38. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated March 8, 2022

39. National Federation of Municipal Analysts: Letter from Lisa S. Good dated March 8, 2022

40. New Jersey Infrastructure Bank: Letter dated March 8, 2022

41. New York City Housing Development Corporation: Letter from Ellen K. Duffy, EVP Debt Issuance & Finance

42. PFM Financial Advisors, LLC: Letter from Cheryl Maddox, Chief Legal and Compliance Officer, and Daniel Hartman, Chief Executive Officer, dated March 7, 2022

43. PIMCO: Letter from David Hammer, Managing Director and Head of Municipal Bond Portfolio Management, dated March 4, 2022\

44. Principles for Responsible Investment: Letter from Greg Hershman, Head of US Policy, dated March 8, 2022

45. Public Finance Initiative: Letter from Lourdes German, Executive Director, dated March 8, 2022

46. San Francisco Public Utilities Commission: Letter

47. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated March 8, 2022

48. Sperry Capital Inc.: Letter from Bryant Jenkins, Principal, dated March 8, 2022

49. State of Florida, Division of Bond Finance: Letter dated March 8, 2022

50. State of Wisconsin, Department of Administration: Letter from David R. Erdman, Capital Finance Director, dated March 8, 2022

51. TIAA: Letter from Amy M. O'Brien, Executive Vice President, Head of Responsible Investment, and Yves P. Denize, Senior Managing Director, Division General Counsel, dated March 8, 2022

52. Utah State Treasurer et al.: Letter dated March 8, 2022

 

Notice 2021-12 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

All Comments to Notice 2021-12

1. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated January 19, 2022

2. First River Advisory L.L.C.: Letter from Shelley J. Aronson dated January 18, 2022

3. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 19, 2022

4. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Matthew Roberts, Assistant Vice President, dated January 19, 2022

Notice 2021-08 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers, Dealers, Municipal Advisors

All Comments to Notice 2021-08

1. American Securities Association: Letter from Christopher A. Iacovella, Chief Executive Officer, dated June 28, 2021

2. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated June 28, 2021

3. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated June 28, 2021

4. Szaro, Jennifer: Email dated May 17, 2021

Notice 2021-07 - Request for Comment
Publication date: | Comment due:
Rule Number:

Rule G-17

All Comments to Notice 2021-07

1. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated June 17, 2021

2. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated June 17, 2021

3. Third-Party Marketers Association: Letter from Donna DiMaria, Chairman of the Board of Directors and Chair of the 3PM Regulatory Committee, dated June 16, 2021

Notice 2021-06 - Request for Comment
Publication date: | Comment due:
Information for:

Bank Dealers

Rule Number:

Rule G-19

All Comments to Notice 2021-06

1. American Bankers Association: Letter from Justin M. Underwood, Executive Director - ABASA, Vice President, Banking Policy, dated June 2, 2021

2. American Securities Association: Letter from Christopher A. Iacovella, Chief Executive Officer, dated May 27, 2021

3. Capital Markets Group of Commerce Bank: Letter from Erik Swanson, Managing Director, and Joseph Reece, Chief Compliance Officer

4. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated June 2, 2021

Notice 2011-63 - Request for Comment
Publication date: | Comment due:

1.  Alternative Regulatory Solutions, L.L.C.: Letter from Kimberly McManus, President, dated December 13, 2011

2.  Bond Dealers of America: Letter from Michael Nicholas, CEO, dated December 13, 2011

3.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated December 13, 2011

4.  TMC Bonds L.L.C.: Letter from John S. Craft, Director of Sales and Marketing, dated December 13, 2011

Notice 2011-50 - Request for Comment
Publication date: | Comment due:
Rule Number:

Rule G-8, Rule G-9


1.  Bond Dealers of America: Letter from Michael Nicholas, Chief Executive Officer, dated November 3, 2011

2.  Dolan, Tom: Letter dated October 21, 2011

3.  Hartfield, Titus & Donnelly, LLC: Letter from Mark J. Epstein, President and CEO, dated November 3, 2011

4.  Knight BondPoint: Letter from Marshall Nicholson, Managing Director, dated November 3, 2011

5.  Regional Brokers, Inc.: Letter from Joseph A. Hemphill III, President, and H. Deane Armstrong, CCO, dated November 1, 2011

6.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated November 2, 2011

7.  TMC Bonds L.L.C.: Letter from Thomas S. Vales, Chief Executive Officer, dated November 3, 2011

8.  Vista Securities, Inc.: Letter from Paul Larkin, President, dated November 1, 2011

9.  Wolfe & Hurst Bond Brokers, Inc.: Letter from O. Gene Hurst, President, dated November 3, 2011

Notice 2011-41 - Request for Comment
Publication date: | Comment due:
Notice 2011-42 - Request for Comment
Publication date: | Comment due:


1.  National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated September 14, 2011

2.  WM Financial Strategies: Letter from Joy A. Howard, Principal, dated September 13, 2011

Notice 2011-34 - Request for Comment
Publication date: | Comment due:
Rule Number:

Rule A-11

1.  Kaplan Financial Consulting, Inc.: E-mail from Dan Kaplan, dated July 29, 2011

2.  Kitahata & Company: E-mail from Gary Kitahata, Principal, dated July 26, 2011

3.  National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated August 29, 2011

4.  National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated September 12, 2011

5.  Repsholdt, John V.: Letter dated August 29, 2011

6.  Securities Industry and Financial Markets Association: Letter from Michael Decker, Managing Director, dated September 12, 2011

Notice 2011-33 - Request for Comment
Publication date: | Comment due:

  1. Coalition of Mutual Fund Investors: Letter from Niels Holch, Executive Director, dated August 31, 2011
  2. College Savings Foundation: Letter from Roger Michaud, Chairman, dated August 31, 2011
  3. College Savings Plans Network: Letter from Joan Marshall, Chair, dated August 31, 2011
  4. Investment Company Institute: Letter from Tamara K. Salmon, Senior Associate Counsel, dated August 31, 2011
  5. Morningstar, Inc.: Letter from Laura Pavlenko Lutton, Editorial Director, Fund Research Group, dated August 31, 2011
  6. Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated August 26, 2011
  7. Stable Value Consultants: E-mail from Christopher B. Tobe, dated July 21, 2011
  8. Sutherland Asbill & Brennan LLP: Letter from Michael Koffler, dated August 31, 2011
  9. Virginia College Savings Plan: Letter from Mary G. Morris, Chief Executive Officer, dated August 31, 2011
  10. Wells Fargo Funds Management, LLC: Letter from Andrew N. Owen, Executive Vice President, dated August 31, 2011
     
Notice 2011-28 - Request for Comment
Publication date: | Comment due:
Rule Number:

Rule G-8, Rule G-9

1.  Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated June 24, 2011

2.  Bradley Payne LLC: Letter from John B. Payne, Principal, dated May 25, 2011

3.  Dixworks LLC: Letter from Dennis Dix, Jr., Principal, dated June 1, 2011

4.  First Southwest: Letter from Robert Coulter, Senior Vice President, Chief Administrative Officer, dated June 23, 2011

5.  Leigh Fisher: Letter from Nicholas Davidson, President, dated June 22, 2011

6.  National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated June 24, 2011

7.  Securities Industry and Financial Markets Association: Letter from David L. Cohen, Managing Director, Associate General Counsel, dated June 24, 2011

8.  Third Party Marketers Association: Letter from Lisa Roth, Board Director, dated June 13, 2011

Notice 2011-18 - Request for Comment
Publication date: | Comment due:


1.  American Municipal Securities, Inc.: Letter from John C. Petagna, Jr., President, dated April 26, 2011

2.  Barker, Bill: E-mail dated April 18, 2011

3.  Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated April 21, 2011

4.  Chapdelaine & Co.: Letter from August J. Hoerrner, President, dated May 5, 2011

5.  Conners & Company, Inc.: E-mail from Jay White dated April 13, 2011

6.  Foard, Dale: E-mail dated April 21, 2011

7.  Hartfield, Titus & Donnelly, LLC: Letter from Mark J. Epstein, President and Chief Executive Officer, dated April 21, 2011

8.  KeyBanc Capital Markets Inc.: E-mail from Michael A. Burrello, Managing Director, Municipal Trading and Underwriting, dated April 21, 2011

9.  Kiley Partners, Inc.: E-mail from Michael Kiley dated April 12, 2011

10.  Knight BondPoint: Letter from Marshall Nicholson, Managing Director, dated April 21, 2011

11.  M.E. Allison & Co., Inc.: E-mail from Christopher R. Allison, Chief Financial Officer, dated April 20, 2011

12.  National Alliance Securities: E-mail from Bob Barnette, Municipal Trader, dated April 21, 2011

13.  Oppenheimer & Co., Inc.: Letter from Marty Campbell, Senior Director, Municipal Underwriting & Trading

14.  Potratz, Jay: E-mail dated April 21, 2011

15.  R. Seelaus & Co., Inc.: E-mail from Richard Seelaus dated April 13, 2011

16.  Regional Brokers, Inc.: Letter from Joseph A. Hemphill, III, CEO, and H. Deane Armstrong, CCO, dated April 21, 2011

17.  Regional Brokers, Inc.: Letter from Joseph A. Hemphill, III, President and CEO, and H. Deane Armstrong, CCO, dated May 12, 2011

18.  RH Investment Corporation: Letter from Andrew L. "Bud" Byrnes, III, Chief Executive Officer, dated April 21, 2011

19.  Robbins, Leonard Jack: Letter dated May 1, 2011

20.  RW Smith & Associates, Inc.: Letter from Paige W. Pierce, President and CEO, dated April 27, 2011

21.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated April 29, 2011

22.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated April 29, 2011

23.  Seidel & Shaw, LLC: Letter from Thomas W. Shaw, President

24.  Sentinel Brokers Company, Inc.: E-mail from Joseph M. Lawless, President, dated April 12, 2011

25.  Sentinel Brokers Company, Inc.: E-mail from Joseph M. Lawless, President, dated April 13, 2011

26.  Seven Points Capital: E-mail from Jerry Racasi dated April 13, 2011

27.  Stifel, Nicolaus & Company, Incorporated: E-mail from Andy Jackson dated April 20, 2011

28.  Stoever Glass & Co.: Letter from Frederick J. Stoever, President, dated April 15, 2011

29.  TheMuniCenter, LLC: Letter from Thomas S. Vales, Chief Executive Officer, dated April 21, 2011

30.  Tradeweb Markets LLC: Letter from John Cahalane, Managing Director, Head of Tradeweb Retail, dated May 3, 2011

31.  Walsh, John: E-mail dated April 21, 2011

32.  Wiley Bros.-Aintree Capital, LLC: E-mail from Keener Billups, Managing Director, dated April 26, 2011, corrects Wiley Bros.-Aintree Capital, LLC: E-mail from Keener Billups, Managing Director, dated April 13, 2011

33.  William Blair: E-mail from Tom Greene dated April 21, 2011

34.  Welbourn, Steve: E-mail dated April 21, 2011

35.  Wolfe & Hurst Bond Brokers, Inc.: Letter from O. Gene Hurst, President, dated April 25, 2011, corrects Wolfe & Hurst Bond Brokers, Inc.: Letter from O. Gene Hurst, President, dated April 21, 2011

36.  Ziegler Capital Markets: E-mail from Kathleen R. Murphy dated April 13, 2011

Notice 2011-16 - Request for Comment
Publication date: | Comment due:


1. Catholic Finance Corporation: Letter from Michael P. Schaefer, Executive Director, dated February 16, 2011

2. Catholic Finance Corporation: Letter from Michael P. Schaefer, Executive Director, dated April 5, 2011

3. Fisher, Robert: E-mail dated April 6, 2011

4. Municipal Regulatory Consulting LLC: Letter from David Levy, Principal, dated April 1, 2011

5. National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated April 1, 2011

6. Public Financial Management, Inc.: Letter from Joseph J. Connolly, General Counsel, dated April 4, 2011

7. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated April 5, 2011

8. WM Financial Strategies: Letter from Joy A. Howard, Principal, dated April 2, 2011

Notice 2011-12 - Request for Comment
Publication date: | Comment due:
Rule Number:

Rule G-17


1.  American Federation of State, County and Municipal Employees: Letter from Gerald W. McEntee, International President, dated April 11, 2011

2.  Bond Dealers of America: Letter from Mike Nicholas, Chief Executive Officer, dated April 11, 2011

3.  Municipal Regulatory Consulting LLC: Letter from David Levy, Principal, dated April 11, 2011

4.  National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated April 11, 2011

5.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated April 11, 2011

Notice 2011-13 - Request for Comment
Publication date: | Comment due:
Rule Number:

Rule G-17

1.  American Federation of State, County and Municipal Employees: Letter from Gerald W. McEntee, International President, dated April 11, 2011

2.  American Governmental Financial Services: E-mail from Robert Doty, President, dated April 11, 2011

3.  B-Payne Group: Letter from John B. Payne, Principal, dated March 28, 2011

4.  Catholic Finance Corporation: Letter from Michael P. Schaefer, Executive Director, dated April 11, 2011

5.  Municipal Regulatory Consulting LLC: Letter from David Levy, Principal, dated April 11, 2011

6.  National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated April 11, 2011

7.  Not For Profit Capital Strategies: E-mail from Ed Crouch, dated February 14, 2011

8.  Public Financial Management: Letter from Joseph J. Connolly, General Counsel, dated April 8, 2011

9.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated April 11, 2011

Notice 2011-14 - Request for Comment
Publication date: | Comment due:


1.  American Bankers Association: Letter from Cristeena G. Naser, Senior Counsel, dated April 11, 2011

2.  American Council of Engineering Companies: Letter from David A. Raymond, President and CEO, dated April 11, 2011

3.  American Federation of State, County and Municipal Employees: Letter from Gerald W. McEntee, International President, dated April 11, 2011

4.  American Governmental Financial Services: E-mail from Robert Doty, President, dated April 11, 2011

5.  B-Payne Group: Letter from John B. Payne, Principal, dated March 28, 2011

6.  Education Finance Council: Letter from Vince Sampson, President, dated April 11, 2011

7.  Fi360: Letter from Blaine F. Aikin, CEO, and Kristina A. Fausti, Director of Legal and Regulatory Affairs, dated April 11, 2011

8.  Lewis Young Robertson & Burningham, Inc.: Letter from Scott J. Robertson, Principal, dated April 11, 2011

9.  Michigan Bankers Association: Letter from Richard D. Lavolette, General Counsel

10.  Municipal Regulatory Counsulting LLC: Letter from David Levy, Principal, dated April 11, 2011

11.  National Association of Independent Public Finance Advisors: Letter from Colette J. Irwin-Knott, President, dated April 11, 2011

12.  Not For Profit Capital Strategies: E-mail from Ed Crouch, dated February 14, 2011

13.  Phoenix Advisors, LLC: E-mail from Peter G. Egan, Managing Director, dated March 3, 2011

14.  Phoenix Advisors, LLC: E-mail from Peter G. Egan, Managing Director, dated March 4, 2011

15.  Public Financial Management: Letter from Joseph J. Connolly, General Counsel, dated April 8, 2011

16.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated April 11, 2011

17.  Wisconsin Bankers Association: Letter from Rose Oswald Poels, Interim CEO/President, dated April 11, 2011

Notice 2011-04 - Request for Comment
Publication date: | Comment due:

1.  Acacia Financial Group, Inc.: Letter from Kim M. Whelan, Co-President, dated February 25, 2011

2.  American Bankers Association: Letter from Cristeena G. Naser, Senior Counsel, dated February 25, 2011

3.  American Governmental Financial Services: E-mail from Robert Doty, President, dated March 1, 2011

4.  BMO Capital Markets GKST Inc.: Letter from Robert J. Stracks, Counsel, dated February 25, 2011

5.  Callcott, W. Hardy: Letter dated February 8, 2011

6.  Fisher, Robert: E-mail dated February 25, 2011

7.  G.L. Hicks Financial LLC: E-mail from Dareth Goulding, dated January 14, 2011

8.  H.J. Umbaugh & Associates: Letter from Gerald G. Malone, dated February 24, 2011

9.  National Association of Independent Public Finance Advisors: Letter from Colette Irwin-Knott, President, dated February 24, 2011

10.  Repex & Co., Inc.: E-mail from Erich Sokolower, dated January 14, 2011

11.  Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated February 25, 2011

12.  State of Texas: Letter from Susan Combs, Texas Comptroller of Public Accounts, dated February 25, 2011

13.  State of Texas: Letter from Charles B. McDonald, Assistant Attorney General, Office of Attorney General of Texas, dated February 25, 2011

14.  T. Rowe Price: Letter from David Oestreicher, Chief Legal Counsel, dated February 25, 2011

15.  The PFM Group: Letter from Joseph J. Connolly, General Counsel, dated February 23, 2011

16.  WM Financial Strategies: Letter from Joy A. Howard, Principal, dated February 21, 2011

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