Subject: File No. S7-18-09
From: Leslie F Bond, Jr
Affiliation: CEO, Attucks Asset Management

September 14, 2009

Attucks Asset Management is a Registered Investment Adviser with The SEC. Attucks was formed in 2001 and specializes in creating manager-of-emerging manager portfolios. We consider an emerging manager to be an investment advisory firm with less than $2 billion assets under management.We are one the most highly regarded firms in this investment space with assets under management of approximately $1.1 billion with more than 35 emerging managers in 12 institutional investment portfolios.Our mission is to build a bridge between institutional investment responsibility and opportunities for new and smaller investment management firms.In these types of programs we share our fees with the underlying managers. Although we are compensated by our investors for overseeing and evaluating emerging managers we provide real services and assistance to our emerging managers at no additional cost to them.These kinds of programs should not be within the scope of any prohibition on firms splitting fees because we actually create value for the investors and the managers.If any 3rd party marketer claims they help emerging firms its news to me.