Subject: File No. S7-36-11
From: Joseph A Ertel, DVM CBI
Affiliation: Practicing Veterinarian and Business Broker, Legacy Advisors Group

October 28, 2011

I assist small business owners and buyers ($200,000-$2,000,000) in selling and purchasing these businesses.

Each transaction is unique, however especially in these times a degree of owner financing is usually necessary.

Some interprupt the SEC rules as making this a Security Transaction.

These transactions are necessary for the normal transitions in the business world and have been performed by experienced Business Brokers for decades.

For the sake of everybody ( Business Owners, Business Buyers, Clients , Cuistomers, Etc.) Please address this problem and allow licensed Business Brokers to perform the necessary services to facilitate the transition of Businesses

Joseph Ertel DVM CBI