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Independent Registered Municipal Advisor Exemption Letter

Independent Registered Municipal Advisor (IRMA) Exemption Letter

Erie County Comptroller’s Office


By publicly posting the following written disclosure, the Erie County Comptroller (“Comptroller) intends that market participants may receive and use it for purposes of qualifying for the independent registered municipal advisor exemption to the U. S. Securities and Exchange Commission Municipal Advisor Rule (in accordance with Section 15B(e)(4)(c) of the Securities Exchange Act of 1934) until otherwise withdrawn or replaced by the Comptroller’s Office.


The Erie County Comptroller (the “Comptroller” or “Issuer”) has retained Masterson Advisors LLC (“Municipal Advisor”) to provide advice on recommendations and other advice received from financial services firms concerning the issuance of municipal securities and municipal financial products for Erie County, New York.  The Issuer will rely on the Municipal Advisor by seeking and considering its advice, analysis, and perspective before acting on any recommendation or other advice, although the Issuer may not necessarily follow the Municipal Advisor’s advice and may also rely on representations, if any, made by financial services firms in proposals made to the Issuer in reliance upon this letter.


Financial services firms that wish to learn the identity of individuals at the Municipal Advisor who will participate in advising the Issuer (so that they may determine whether the Municipal Advisor is independent) should contact Steven Kantor at the address set forth below. A copy of written representations regarding the exemption may also be sent to the Municipal Advisor at the same address:


Steven Kantor

Masterson Advisors LLC

2310 Tradition Way, Unit 201

Naples, Florida 34105



If you have any questions about this letter, please contact:


Timothy Callan

Deputy Comptroller

Erie County Comptroller’s Office

95 Franklin Street, 11th Floor

Buffalo, New York 14202