Subject: File No. S7-18-11
From: John J Cadigan
Affiliation: Captain, USCG (Retired) General Partner, CECO LLC

June 15, 2011

As one who generally favors LESS governmental regulation, I nevertheless applaud the proposed profesional standards.

I received my first "Visa" card in 1968. I have always had several cards since then, and after retirement from over thirty years service in the military in 1985 I used the cards extensively to build and support our family business ventures. I have never missed a payment on credit cards, mortgage loans, car loans, boat loans, or any other loan. My net worth is in seven figures.

Bank inquiries to support annual Lines of Credit, new purchases, as well as all other loans and payoffs, coupled with a frequent high balance of credit, all combine to drag down my credit score to typically hover between 655 and 700.

So even with a perfect payment record of payments and on-time(or before)loan payoffs stretching well over forty years, my "credit worthiness" is still only about "average," or "good" by virtue of the arbitrary formulae of the credit rating industries.

I therefore strongly support regulating this industry which so greatly impacts my financial conduct of business, and revamping the formulae used and weight of the various factors included.