Subject: File No. 4-606
From: Michael F. Starshak
Affiliation: Board/Finance Committee Member, American Red Cross of East Central WI, Chairman - Community Health Network Foundation, Board/Finance Committee Member - Thrasher Opera House, Green Lake WI, Contributing Finance Writer - The Berlin Journal Newspapers

July 27, 2010

In 1994 I became a Registered Investment Advisor in Illinois with a national filing with the SEC under the Investment Advisors Act of 1940. Later, registration rules allowed advisors with lesser assets under management to be state-only registered. In 2001 I accepted the position of consultant to a bank in central Wisconsin and later accepted the position of manager of their investment services department. This position required my registration as a series 7 broker. Due to my experience with registrations under both the advisor and broker designations, i believe I am uniquely qualified to provide insight into these two similar, but different financial services careers.

The growth of regulation and compliance procedures in the last decade have presented both confusion on the part of the client, and irritation on the side of honest hard-working professionals. Historically, regulation has not prevented corrupt agents or financial services firms from acting in their own best interests. The best deterrent from illegal activities is the resultant loss of income and a career, not the threat of incarceration. It is unfortunate that the growth of regulation has added several layers of costs to the final end user while not significantly improving the service provided them. Additionally, this growing regulation is preventing new entrants into the marketplace, particularly the small business owner.

In the last 25 years, the greatest growth of jobs has been in the small business sector. Small business, by definition, has more at stake in the loss of clients than a larger corporation. Why not encourage new entrants? Large financial services corporations ("LFSC's)have seen the growth of independent advisors as a threat to their business. This view has been supported by LFSC's past public statements that that the independent advisory business would not survive and to some small extent, implying that their business model could not survive. These statement were made during the market boom years of the 1990's. Today we have seen significant growth of independent advisors and the LFSC's competing to both service this market and actively acquire them.

I would be more than happy to testfiy before any committee regarding my years of experience in the financial services industry and answer any questions.

Thank you for your efforts.