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Notice 2022-13 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments to Create an Exemption for Municipal Advisor Representatives from Requalification by Examination
Information for:

Issuers, Municipal Advisors

Rule Number:

Rule G-3

All Comments to Notice 2022-13

  1. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 30, 2023
  2. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated January 30, 2023
  3. Wulff, Hansen & Co.: Letter from Chris Charles, President, dated December 29, 2022
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Notice 2022-11 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments to MSRB Rule G-32 to Streamline the Deadlines for Submitting Information on Form G-32
Rule Number:

Rule G-32

All Comments to Notice 2022-11

  1. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, January 17, 2023
  2. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, dated January 27, 2023
  3. XBRL US: Letter from Campbell Pryde, President and CEO, dated December 15, 2022
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Notice 2022-07 - Request for Comment
Publication date: | Comment due:
Request for Comment on Transaction Reporting Obligations under MSRB Rule G-14
Information for:

Bank Dealers

Rule Number:

Rule G-14

All Comments to Notice 2022-07

  1. American Securities Association: Letter from Kelli McMorrow, Head of Government Affairs, dated September 30, 2022
  2. Amuni Financial, Inc.: Letter from Mike Petagna, President, dated August 23, 2022
  3. Bailey, Bill: Email dated August 4. 2022
  4. Belle Haven Investments, L.P.: Letter from Matt Dalton, Chief Executive Officer, dated October 3, 2022
  5. Bernardi Securities, Inc.: Letter from Ronald P. Bernardi, President and CEO, dated September 30, 2022
  6. BetaNXT: Letter from Will Leahey, Head of Regulatory Compliance, dated October 3, 2022
  7. Bond Dealers of America: Letter from Michael Decker, Senior Vice President for Public Policy, dated October 3, 2022
  8. Bryant Bank: Letter from David Long, Executive Vice President, Correspondent Banking/Capital Markets, and Vincent Webb, Managing Director, Bryant Bank Capital Markets, dated September 28, 2022
  9. Cambridge Investment Research, Inc.: Letter from Seth A. Miller, General Counsel, President, Advocacy and Administration, dated October 3, 2022
  10. Cantella & Co., Inc.: Email from Jay Lanstein, Chief Executive Officer and Chief Technology Officer, dated September 16, 2022
  11. Cantone Research, Inc.: Email from Maryann Cantone dated August 2, 2022
  12. Colwell, J.D.: Letter dated September 9, 2022
  13. DeRobbio, Raymond: Email dated August 3, 2022
  14. Dimensional Fund Advisors LP: Letter from Gerard O’Reilly, Co-CEO and Chief Investment Officer, and David A. Plecha, Global Head of Fixed Income, dated September 26, 2022
  15. Estrada Hinojosa & Co., Inc.: Letter from Robert A. Estrada, Chairman (Emeritus), dated October 3, 2022
  16. Falcon Square Capital, LLC: Letter from Melissa P. Hoots, CEO/CCO, dated October 3, 2022
  17. Financial Information Forum: Letter from Howard Meyerson, Managing Director, dated October 3, 2022; Supplemental Letter from Howard Meyerson, Managing Director, dated April 27, 2023
  18. Ford & Associates, Inc.: Letter from Jonathan W. Ford, Senior Vice President, dated September 9, 2022
  19. Hartfield, Titus & Donnelly, LLC: Letter from Edward J. Smith, General Counsel and Chief Compliance Officer, dated September 14, 2022
  20. Herbert J. Sims & Co., Inc.: Letter from Melissa Messina, Executive Vice President, Associate General Counsel, R. Jeffrey Sands, Managing Principal, General Counsel, and William Sims, Managing Principal, dated October 3, 2022
  21. Higgins Capital Management, Inc.: Email from Deborah Higgins dated September 19, 2022
  22. Hilltop Securities: Letter from Lana Calton, Executive Managing Director, Head of Clearing, dated October 3, 2022
  23. Honey Badger Investment Securities, LLC: Letter from Joe Lee, CEO, dated September 30, 2022
  24. ICE Bonds Securities Corporation: Letter from Robert Laorno, General Counsel, dated September 30, 2022
  25. InspereX LLC: Letter from Robert D. Bullington, Vice President, Compliance Officer, dated October 3, 2022
  26. Institutional Securities Corporation: Letter from Scott Hayes, President and CEO, and Chris Neidlinger, CCO, dated September 30, 2022
  27. Investment Company Institute: Letter from Sarah A. Bessin, Associate General Counsel, dated October 3, 2022
  28. Investment Placement Group: Email from Darius Lashkari dated August 2, 2022
  29. Isaak Bond Investments: Letter from John Isaak, Sr. Vice President, dated August 16, 2022
  30. Isaak Bond Investments, Inc.: Letter from Donald J. Lemek, VP-Operations and CFO
  31. Kiley Partners, Inc.: Email from Mike Kiley, Owner, dated September 27, 2022
  32. Madison Paige Securities: Letter from Gary Herschitz, CEO, dated September 30, 2022
  33. Mayes, Christopher: Email dated September 27, 2022
  34. Miner, Kathy: Letter dated October 2, 2022
  35. Municipal Securities Rulemaking Board: Memorandum dated September 12, 2022
  36. Northland Securities Inc.: Letter from Randy Nitzsche, President and CEO, dated October 3, 2022
  37. Oberweis Securities, Inc.: Letter from James W. Oberweis, President, dated September 28, 2022
  38. Regional Brokers, Inc.: Letter from H. Deane Armstrong, CCO, and Joseph A. Hemphill III, CEO, dated October 3, 2022
  39. Robert Blum Municipals, Inc.: Letter from Robert Blum, President, dated September 16, 2022
  40. Roosevelt & Cross, Inc.: Letter from F. Gregory Finn, Chief Executive Officer, dated October 3, 2022
  41. RW Smith & Associates, LLC: Letter from Christopher Ferreri, President, dated September 13, 2022
  42. SAMCO Capital Markets, Inc.: Letter from Lee Maverick, Chief Compliance Officer, dated September 30, 2022
  43. Sanderlin Securities LLC: Letter from Matthew Kamler, President, dated September 27, 2022
  44. Securities Industry and Financial Markets Association and the SIFMA Asset Management Group: Letter from Kenneth E. Bentsen, Jr., President and CEO, dated October 3, 2022
  45. Sentinel Brokers Company, Inc.: Letter from Joseph Lawless, CEO, dated September 30, 2022
  46. Sheedy, Edward: Email dated August 2, 2022
  47. Stern Brothers and Co.: Letter dated October 3, 2022
  48. TRADEliance, LLC: Letter from Jesy LeBlanc and Kat Miller dated September 28, 2022
  49. Tuma, William: Email dated August 8, 2022
  50. Wells Fargo & Company: Letter from Nyron Latif, Head of Operations, Wells Fargo Wealth and Investment Management, and Todd Primavera, Head of Operations, Wells Fargo Corporate and Investment Bank, dated October 3, 2022
  51. Wiley Bros.-Aintree Capital, LLC: Letter from Keener Billups, Managing Director, Municipal Bond Department, dated September 20, 2022
  52. Wintrust Investments, LLC: Email from Thomas Kiernan dated August 2, 2022
  53. Zia Corporation: Email from Glenn Burnett dated September 6, 2022
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Notice 2011-63 - Request for Comment
Publication date: | Comment due:
Request for Comment on Restated Sophisticated Municipal Market Professional Notice
Rule Number:

Rule G-13, Rule G-17, Rule G-18, Rule G-19

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

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Notice 2011-50 - Request for Comment
Publication date: | Comment due:
Request for Comment on Revised Draft Rule G-43 (On Broker’s Brokers), Associated Revised Draft Amendments to Rule G-8 (On Books and Records) and Rule G-9 (On Preservation of Records), and Draft Interpretive Notice on the Obligations of Dealers that Use the Services of Broker’s Brokers
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

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Notice 2011-41 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Amendments to MSRB Rule G-21 (on Advertising) and Draft Interpretive Notice Concerning the Application of MSRB Rule G-17 (on Fair Dealing) to Certain Communications
Rule Number:

Rule G-9, Rule G-17, Rule G-21


1.  College Savings Plans Network: Letter from Joan Marshall, Chair, dated September 14, 2011

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

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Notice 2011-42 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Rule G-46 (on Activities of Municipal Advisors)


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

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Notice 2011-34 - Request for Comment
Publication date: | Comment due:
MSRB Files Proposal to Establish Interim Municipal Advisor Assessment and Seeks Comment on Draft Municipal Advisor Survey
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

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Notice 2011-33 - Request for Comment
Publication date: | Comment due:
Request for Comment on Plan to Collect Information on 529 College Savings Plans

  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
     
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Notice 2011-28 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Rule G-44 (On Supervision of Municipal Advisory Activities) and Associated Amendments to Rules G-8 (On Books and Records) and G-9 (On Preservation of Records)
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

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Notice 2011-18 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Broker’s Brokers Rule (Rule G-43) and Associated Recordkeeping and Transaction Amendments
Rule Number:

Rule G-8, Rule G-9, Rule G-18


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

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Notice 2011-16 - Request for Comment
Publication date: | Comment due:
Request for Comment on Gifts and Gratuities Rule for Municipal Advisors
Rule Number:

Rule G-8, Rule G-9, Rule G-20


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

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Notice 2011-14 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft MSRB Rule G-36 (on Fiduciary Duty of Municipal Advisors) and Draft Interpretive Notice


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

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Notice 2011-12 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Interpretive Notice Concerning the Application of MSRB Rule G-17 to Underwriters of Municipal Securities
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

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Notice 2011-13 - Request for Comment
Publication date: | Comment due:
Request for Comment on Draft Interpretive Notice Concerning the Application of MSRB Rule G-17 to Municipal Advisors
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

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Notice 2011-04 - Request for Comment
Publication date: | Comment due:
Request for Comment on Pay to Play Rule (Rule G-42) for Municipal Advisors
Rule Number:

Rule G-8, Rule G-9, Rule G-37, Rule G-38

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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