Subject: File No. S7-15-10

October 15, 2010

Somewhere along the way it became popular to subscirbe to the idea that advice is a commodity. I happen to believe that is false. The work that I do for my clients justifies me making 1% of the value of their accounts. If I am not adding at least that much value then they should move their accounts elsewhere. I hold quarterly, face to face reviews with my clients in addition to providing them with weekly updates on the market via a newsletter. Additionally, they get special mailings on important topics like a Roth IRA conversion, or the tax changes that will take effect next year without Congress acting in addition to getting quarterly updates via a newsletter.
I want my compensation to be tied to the client`s performance. In this type of arrangement, I can only make more money from the account if the value of the account grows. I lose compensation year over year if the value of the account falls. I have just aligned my personal goals of compensation with the personal goals of the client to make money in their accounts.
The only other way to accomplish this type of compensation agreement is through a wrap account program. Since there are additional fees, in order for me to receive my 1% fee it costs the client more money. This makes no sense whatsoever to take this option off the table as a means for client and advisor to work together.

Mr. Christopher Bice
Bice Wealth Management