Subject: File No. 4-606
From: Charles A. Smith
Affiliation: CEO, Financial Services Firm

July 30, 2010

Fees are inappropriate for 85-90% of American households. Fee-based charges are more expensive for almost every client over time.

Accountability: Customers must not be given a free ride when it comes to being held responsible for their choices and actions.

I have determined that I will only charge fees to clients with over $500,000 of investible assets and then I give them an option.

With 42 years of experience I don't expect that I will remain in this business if all transaction go to a fee basis.

I spend 30-40% of client face to face time meeting compliance requirements. In addition, there is significant material I would love to share with clients but am not allowed because of compliance. The information would clearly be in the client's best interest.

I am examined annually by appointment and once every three years without notice. I have never had an infraction.

When you consider the amount of time involved in compliance and compliance related training it totals more than 40-60 hours per year.

I am solidly opposed to a fee only approach. No one is well served with this move.