Subject: File No. S7-15-10
From: Scott Walton
Affiliation: S. Andrew Walton Investment Planning

October 14, 2010

We run an ethical, service-based practice, based on our clients` invidividual needs and circumstances. We feel it is vital to be able to offer choices in the way(s) our clients pay for our services. One way is through the 12b-1 fee variety. Call them what you may and disclose as much as you feel is appropriate, but, by lowering or removing a clients ability to compensate for services through 12b-1s, will mean our raising rates for all of our clients. Also, it will force many relationships into "fee-based" account types, which, in our opinion isn`t a size that "fits all". Choice is best!

Scott Walton
S. Andrew Walton Investment Planning