Subject: File Number S7-15-10

October 22, 2010

Many of my clients are public school teachers with limited funds for investment in retirement accounts. As such, mutual funds with lower contribution levels are the choice for their portfolios. My only initial compensation is through dealer reallowances of sales charges and my only ongoing compensation as incentive to service the account is through 12b-1 fees. Although I have a true servant mentality, working for free will dramatically reduce my ability to give adequate attention.

Mr. Gary Gray
Registered Rep
Invest Financial