The Clearing House Association submitted, along with the ABA and ABASA, a letter to the SEC on its notice of proposed rulemaking to establish a permanent registration system for municipal advisors under § 975 of Dodd-Frank. While the associations support the goal of ensuring that market participants providing investment advice to municipalities are appropriately regulated, they believe that the proposed rules go beyond legislative intent and public policy need by regulating already-regulated traditional banking products that are outside the ambit of § 975. The letter encourages the SEC to (i) state clearly that traditional banking products and services are not covered by § 975, (ii) provide an exemption from § 975 requirement for advisory activities that would be exempt were banks required to register as advisers under the Advisers Act, and (iii) rethink its proposal to exclude appointed members of a municipality’s governing body from the definition of “employee of a municipal entity.”