Subject: File No. 265-27
From: Stephen D Stull

January 31, 2012

Dear Advisory Committee,

After diligent thought on this issue, I urge the committee to support the following proposals:
1) Include public accountants in the role of small enterprise funding.
2) Create a securities license that requires a fiduciary standard for those involved in facilitating the small enterprise fundraising transaction (i.e. the broker or small enterprise investment banker).

As a registered investment advisor, I have been pitched many outstanding small business ideas. The most recent presentation involved a small business that would have created manufacturing jobs (5-8 jobs total) that would compete directly with Chinese manufacturer for a specific automotive component (I believe they would win that competition). However, as is the case with most of these proposals, angel investors are unwilling to tie up capital for a capped return. If a small enterprise cannot be scaled to eventually go public, then angel investors are not interested in providing capital even if returns on investment would be upwards of 16-18% a year with return of capital in 3-5 years.

One of the greatest assets of the US is adequate allocation of capital. I urge the SEC to use the power of the fiduciary standard and the strength of the AICPA to foster more efficient use of capital in the role of small enterprise funding.

Best Regards,
Stephen Stull
Storehouse Financial LLC