Subject: File No. S7-15-10
From: Charles Minnich, CFA

September 7, 2010

Any new rule should not change existing accounts and client relationships. Permanent grandfathering is needed to preserve business models and client relationships that were regulated and legally disclosed by prospectus. Many smaller accounts that do not qualify for fee-based business models could be abandoned and clients would lose guidance and advice in an environment when it is needed most.

If rules are changed in the future, both client and advisor can decide whether to enter into a relationship based on fuly disclosed costs and fees.