Subject: File No. S7-18-09
From: Hal Tabb

August 21, 2009

As I financial advisor who has worked with various pension plans for over 10 years, I believe independent representatives of investment advisors serve as a valuable resource for information that facilitate the investment selection process.

Certainly no one supports any form of "pay to play" or undisclosed payment for placement. Additionally, efforts should be made to sanction any one or any firm involved in such unethical practices. However, my concern is that in the effort to prevent such unethical and illegal practices, you will restrict the valued service provided by legitimate firms or individuals representing investment managers.

Please be aware of the collateral damage that might be done in your effort to control the illegal or undisclosed actions of a limited number of representatives. I believe that a balanced approach must be achieved that restricts and penalizes the offenders while permitting the valued service provide by fully disclosed representatives.