Subject: File No. S7-14-10
From: Noni Menke
Affiliation: Commerce Bank of Arizona

October 13, 2010

To Whom It May Concern:

Commerce Bank of Arizona, Inc., was a de novo bank in 2002, and we now have six branches throughout Arizona. All stock is held in the name of our holding company, CBOA Financial, Inc.

In the midst of our growth over the past eight years, we began trading our stock OTC and also enlisted the services of Continental Stock Transfer & Trust to take over our transfer agent and proxy responsibilities.

Our shareholders and we have found it frustrating that our company does not have access to the list of shareholders who buy CBOA Financial in street name. This has resulted in many new shareholders never receiving a letter of appreciation from the company of their status as shareholder and of these new shareholders never receiving personal communications, periodic updates or proxy ballots that our known individual shareholders enjoy.

We urge you to reform the proxy system by allowing stock issuers to communicate directly with all of their shareholders (both registered and "street" holders); to have access to "street" holders without being compelled to use the Broadridge monopoly, which charges excessive fees and pays rebates back to brokers and banks who send them their business; and to hold their shareholder meetings with assurance that the tabulation process is fair, accurate and transparent, without the errors, over-voting, and broker non-reconciliation which plague the vast majority of all Annual Meetings held each year in the United States.

Finally, we request that the proxy system's reform provide for A FAIR, MARKET-DRIVEN PRICE FOR DISTRIBUTION OF MATERIALS TO STREET HOLDERS!

Sincerely,
Noni Menke

Noni Menke
Vice President, Marketing and Shareholder Liaison
Commerce Bank of Arizona
3805 E Broadway Blvd
Tucson AZ 85716