11710 ADMINISTRATION DRIVE
SUITE 7
ST. LOUIS, MISSOURI 63146
(314) 423-2122
Municipal Securities Rulemaking Board
Attention: Ronald W. Smith
Corporate Secretary
1900 Duke Street Suite 600
Alexandria, VA 22314
Re: Request for Comments to Rule G-20
Ladies and Gentlemen:
April 2, 2011
This letter is in response to the MSRB’s request for comments on the amendments to Rule G-20 relating to gifts and gratuities. WM Financial Strategies is fully supportive of limitations on gifts and gratuities for both municipal advisors and broker-dealers. We believe, however, that Rule G-20 permits pay-to-play by failing to impose a ban on the frequency or value of entertainment that may be provided to employees and elected officials of municipal entities.
Accordingly, we are requesting that, in any year the value of any single gift or gratuity given to any employee or elected official of a municipal entity should not exceed $100 and the aggregate of all gifts, gratuities and entertainment should not exceed $250.
Sincerely,
Joy A. Howard
Principal