Subject: File No. 4-626
From: Todd Genger

July 13, 2011

I appreciate the opportunity to respond to the Securities and Exchange Commission's request for comment to help inform its study of existing public and private investor education efforts ("Study"), as required by Section 917 of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010 ("the Dodd-Frank Act").

My comment addresses the financial literacy of retail investors, including their understanding of the investment process and their ability to make informed investment decisions.

In my experience, most retail investors don't know what they don't know about the investment process. This represents a fundamental challenge to financial literacy programs. Moreover, while the internet is a valuable resource for information, separating fact from fiction and the pervasive problem of industry-sponsored sales and marketing materials posing as investor education is magnified in the digital age.

The most valuable investor education programs are reaching young adults still in school, instilling the building blocks of responsible financial decision making. I believe every school from elementary through college should adopt a thoughtful strategy to help students achieve financial literacy. In partnership with private and public local, regional and national organizations, we can cultivate a nation of students who are conversant in the language of savings, credit, and investment. There are a wealth of successful models to implement the goal of helping students achieve fluency and mastery over their personal finances as they apply their prior skills and training in the "real world".

There are a few standout programs that deserve specific mention and consideration for expansion to a greater audience:

The Stock Market Game sponsored by Securities Industry and Financial Markets Association (SIFMA).

Financial Literacy Training for High School Students, eight independent instructional modules and handouts developed by The Center for Financial Studies at Southern New Hampshire University.

The Gen i Revolution -- an online game developed by the Council for Economic Education to teach personal finance skills to middle and high school students.

The Love Your Money website and online program coordinated by The University of Tennessee Extension Department of Family Consumer Sciences in partnership with The University of Florida, Kansas State University, The University of Kentucky and Mississippi State University.

I commend the SEC for its efforts to encourage programs that inform investors about savings and investing and look forward to other creative solutions that will come out of this comment process.