Subject: File No. S7-15-10
From: John R. Ducar

September 13, 2010

I have many 403b clients who are retired or retiring. In order to remove their investments after retiring, they nust go through a multi-step process of converting their 403bs to an IRA in order to wirhdraw funds when they wish. This thakes much time and the cients are always appreciative. Also, they need help in adjusting their portfolios before and after retirement. As teachers, they depend on us to make changes and keep track of their investments. WHO WILL DO THIS?

John R Ducar