Subject: File No. 4-606
From: William R Cline, CPA
Affiliation: Texas Association of Certified Public Accountants

August 29, 2010

It is my opinion that most investors do not understand the difference between brokers and investment advisors. My experience has been that many elderly clients have relied on investment brokers and dealers and later found they were locked into very long-term investments and their funds were unavailable without experiencing substantial loss of interest and in some cases loss of principle. Investors in their eighties are usually not well advised to invest in annuity contracts. Many elderly clients have taken investments in such contracts because of very low interest rates in certificates of deposit. Being in their advanced years these clients require access to substantial cash when a nursing home becomes necessary. These issues either are poorly communicated by broker dealers or the elderly simply do not hear the caution that should be made.