Comments to the SEC on Registration of Municipal Advisors

The Academy's Pension Practice Council and Public Plans Subcommittee submitted a comment letter to the U.S. Securities and Exchange Commission requesting that public pension plans be excluded from the definition of "investment strategies" and that enrolled actuaries and members of the five U.S.-based actuarial organizations be excluded from the definition of "municipal advisors" to the extent they are providing actuarial services that are governed by the Actuarial Standards of Practice and the Code of Professional Conduct.