Subject: File No. S7-15-10
From: David G Monkelien, CFP

September 10, 2010

A recent article by Oren Peretz in Investment News , Sept 6, 2010, brought up some excellent points on this subject. The idea of updating this system is fine, but the thinking that there will be no problems with the new proposal is unthinkable. The concept of a permanent grandfathering of existing assets deserves a lot of merit. It will preserve business models and client relationships that are in existence. Please read this article and take all of it into consideration before you proceed.