Subject: File No. S7-33-11
From: Polly J Sidwell
Affiliation: Financial Advisor, CIMA (r)

November 15, 2011

I represent the everyday investor, with a 32 year background in fixed-income professions. Please help advisors and clients understand the difference of implicit leverage vs economic leverage and the 1940 Act protection of derivs for protective use for investors. ICI's 11-7-11 release provides excellent investment industry perspective and recommendations.
Feel fre to call me - thank you for your efforts to inform and protect mutual fund investors -- Polly Sidwell [phone number redacted] 1st VP, CIMA, Wealth Mgmt Sr Investment Mgmt Consultant, Morgan Stanley Smith Barney, Seattle, WA 98101