Subject: File No. 4-610
From: Geri M letti

December 7, 2010

Having been a Muni /Treas investor since approximate.1981, the largest single fundamental threat to the Muni markets in particular, is the instability and flash type crashes (as witnessed in the most recent Nov, 2010 precipitous drop in the Muni market) caused by, institutional, not retail, mutual fund/ hedge fund selling/swapping of huge muni blocks via computerized trading. Instability in the Muni markets is further exacerbated by the fact that retail munis are still valued at lower, more volatile institutional prices. Munis have to be stable in pricing and not treated like stocks. Munis are primarily a function of time and the credit quality of the underlying issuer, not a function of trading by mutual funds and/or hedge funds.