Subject: File No. 4-538
From: Warren K. Nelson, MA, LUTCF
Affiliation: Investment Advisor Representative

July 10, 2007

For the past 21 years, I have been previleged to guide middle income Americans with their retirement, financial, trust, and insurance programs. Unfortunately, in todays investment environment, most of my clients are overwhelmed with the variety and sheer volume of investment and insurances choices. Until we meet, most have never seen an advisor who assisted and educated them. I also have 13 years of government experience prior to becomming a registered rep. I am very aware of the needs to protect the consumer and agree that abuses occur in our profession. Regrettably, I have also learned that unethical people don't care about regulations or legal procedures and frequently ignore them. The opposite is also true ethical advisors/reps follow procedures, having from the beginning of their relationship, their clients interests as the sole priority.
As an IAR, my compensation, including 12-B-1 fees, is reviewed with my client at point of purchase. If another form is required to confirm this is completed, I'm sure the client will sign it along with the numerous other forms. However, does anyone really think that another form will help them understand the fee structure if it isn't properly explained to them in the first place? I've seen my clients gloss over forms almost as though they are signing for a new mortgage. Without proper explanation, how many people understand those forms or understood what they were signing? In closing, I support efforts to assist middle income/educated Americans in understanding investment fee options I urge you to consider in your deliberation, my position that the best approach in protecting client interests is to first have an educated, honest advisor serving our clients and secondly, please don't bog them down with more paperwork.