Subject: File No. 4-606
From: Thomas A Crow
Affiliation: Registered Investment Advisor

December 17, 2010

Two things for now:

We are completely independent, not affiliated with any broker-dealer, insurance or mutual-fund company. We sell no commissioned products. As such we can truly tell the client we pursue their best interest. I like that, and so do our clients.

1) I use the fact that I am a fiduciary to differentiate myself from wirehouse brokers and insurance salesmen. I will lose that if we are all lumped into the same category.
I say let the different standards of accountability remain and spend the time and money educating the public on the difference.

2) Please do not kick smaller (less than $100 million) firms down to the state level. The fact that we are currently SEC registered, and have been for many years is another positive, differentiating detail that we can use to our advantage.