Subject: File No. 4-606
From: Bill Staton, MBA, CFA
Affiliation: NC CFA Socieity

August 25, 2010

As a small money manager we face a more and more complicted regulatory environment, and the standards we have to meet are quite high.

We think all so-called advisers from brokers to CPAs to insurance agents selling financial products, anyone who spends time proferring financial advice/products and getting paid for it, should be held to the same rigorous and reporting standards as RIAs.

Thanks for your consideration.

Bill and Mary Staton