Subject: File No. 4-629
From: Robert Grunzinger, CFA, CPA (inactive)
Affiliation: Director, Wheelhouse Securities Corp.

May 12, 2011

It is apparent that the current issuer pay models have an egregious amount of interest conflicts that they should not be relied upon. If an investor needs some reassurance beyond their analysis of a particular investment, then that investor should pay for a conflict free analysis. The market will fill any supply/demand gap for the products and the SEC should allow that to happen on its own.

If there were an established SRO that were to assign a NRSRO to determine credit ratings, we would not rely upon them either.