December 12, 2005

Hon. Jonathan Katz
Securities and Exchange Commission
Re: File Number 265-23

I would like to urge the full SEC Advisory Committee on Smaller Public Companies to adopt the language contained in the Report of the Capital Formation Subcommittee, Section 6, regarding "Research," with the following proviso:

That the full committee further endorse a proposal that research providers referred to in the Section should be those with a transparent, published list of ethics and standards that the investing public may easily and efficiently reference.

This is especially important for company sponsored research. A lack of clear standards, ethics, and transparancy could indicate tainted research results and a product that misleads the public. This lack could affect the reports on companies that do act appropriately with respect to company sponsored research, bad reasearch providers will negatively taint all provider work product. This outcome is not in the interest of any party. Providers should declare the standards they follow as an integral part of their work product.


Robert F. Reisner
Vice Chairman
Shareholders Research Alliance