Subject: File No. 4-606
From: Pamela A Walton, CLU ChFC
Affiliation: MS

August 24, 2010

I have been a registered rep since 1983. I have a series 6,22, and 63. I am monitored always by the company that I represent and have to meet suitability for the products and for the source of funds. They monitor NYL based on age, income, liquid assets and much more. I would not still be in business if I was not working for the best interest of my clients.

Fee-based services were not prevelant when I started and I have chosen to continue servicing my clients as I have in the past. Many of my clients would not be able to afford my services. These fees would increase the cost to my clients. I have my records scrutinized by our in-house, full-time compliance officer routinely.

I feel that I have all the regulations and safe guards needed. Thank you for your attention in this matter.