Subject: File No. 4-626
From: Christopher A Palmer
Affiliation: Independent Financial Advisor (LPL)

May 5, 2011

My comments are in the form of the following questions:

1) Has the definition of a "successful" investment education program for investors been established?

2) Have performance measurements been established for any of the following:
-success rates in terms of attracting investors to take part in the program?
-success rates in terms of investors completing the program?
-success rates in achieving the programs educational objectives?

Thank you

Christopher A. Palmer