Subject: File No. 4-626
From: Amanda O Blanks
Affiliation: Investor Education Coordinator, Virginia Division of Securities

June 21, 2011

The State Corporation Commission's Division of Securities and Retail Franchising is the state agency responsible for the regulation of securities, broker-dealers, broker-dealer agents, investment advisers and their representatives as well as franchises and trademarks in Virginia.

The Division believes that education is the key to making wise investment decisions and avoiding investment fraud. Thus, educating Virginia investors is a priority for the Division. The Divisions Investor Education Program distributes educational information in the form of publications, brochures and teaching guides, and provides presentations, all free of charge.

While the Division provides these educational opportunities at a variety of venues and to all demographics throughout the Commonwealth, for the purposes of this "Comment Request" we will highlight our military outreach initiative.

In 2010 the Division implemented the Investor University on Base program. This program is a modification of a similar program developed by the Florida Office of Financial Regulation.

The Investor University on Base is designed to be a series consisting of four to five sessions lasting between 1.5 and 2 hours each. As requested at most military installations the first session consists primarily of financial basics (setting financial goals, determining net worth, developing a budget, etc.). The second session introduces the key investment principles (paying yourself first, compound interest, risk and return, risk tolerance and diversification) as well as a review of cash equivalent products and their importance. Session three delves into bonds, stocks and mutual funds - what are they, how they work, how to effectively research and their role in one's overall portfolio. The fourth session includes a review on diversification, retirement planning beyond the military, how to seek professional assistance and avoiding investment fraud. When possible, the fifth session includes a presentation on the Thrift Savings Plan by the support staff at the participating military installation.

Between April 2010 and May 2011 the Division has held a total of 14 Investor University on Base series reaching over 500 service men and women and their families. The format and timing for each has been determined by the installation, with some sessions offered in the evenings while others during the day. Participation has been both voluntary and required and the event has been sponsored at different locations by the installation support centers and specific commands.

Through the Investor University on Base the Division has had an opportunity to share in-depth investor education information at the following military locations in the Commonwealth: Naval Air Station Oceana, Naval Station Norfolk, Langley Air Force Base, Fort Eustis and Quantico Marine Base. The Division has also provided investor education publications for distribution at these additional locations: Naval Amphibious Base Little Creek, Dam Neck Annex, Naval Weapons Station Yorktown and US Coast Guard Training Center Yorktown.

The Investor University on Base program will be provided well into the foreseeable future. The service men and women and their families reached through this program are typically young adults who have not received adequate financial education. The Division is dedicated to providing this information and maintaining the ability to effectively make a difference in the service men and women's financial success.