Subject: File Number S7-15-10

October 27, 2010

My name is Nathan McKay and I have been an investment professional for nearly 10 years in Alaska. It is my understanding that the SEC has indicated that allowing broker-dealers to compete based on sales charges and the services they provide will create a level playing field and lead to reduced costs. I, however, am concerned that allowing broker-dealers to compete based on the commissions they charge and the services they provide will lead to a "race to the bottom" causing middle market investors to be overly focused on price and ending up without access to valuable advice and ongoing account services. As broker-dealers slash their fees in an effort to gain market share, it will no longer be financially feasible for registered reps to continue to provide the level of individualized advice and services currently offered. Investors who can afford assets-under-management arrangements or higher cost/higher service classes of shares will continue to receive personalized investment advice, while middle market investors will be deprived of the guidance they need and deserve. This is probably the class of people that the SEC is looking to protect with this measure. I support the transparency of re-naming 12b-1 fees in order to make a more informed client base but the commission based level playing field will simply lead to split the classes of investors further.

Thank you for your consideration.

Nathan T. McKay Sr., LUTCF
Investment Professional
Sound Financial
Registered Representative offering securities through
NYLIFE Securities LLC (member FINRA/SIPC)