Subject: File No. S7-36-11
From: Tracy L Miller

September 13, 2011

One bad apple doesn't spoil the whole bunch. For every unethical advisor, there are hundreds, or even thousands, of honest ones. The extra expense (money and time) and scrutiny are harmful to the small investment professionals who advise investors about defining their objectives and understanding risks. The extra expense is borne by the consumer, either by causing professionals to raise their minimums or by charging higher investment advisory fees. The additional costs of extreme regulation are passed on to advisors, who in order to stay in business, must pass on to consumers. The additional scrutiny and requirement for pre-approval when you want to educate clients about economic environment or strategies to keep their money safe keeps us from timely communication to our clients.

We have stringent continuing education requirements and ethics training requirements, considerable broker-dealer fees, account custody fees, account consolidated reporting fees, software fees, broker-dealer haircut fees, communication review, advertising review, website review, etc. Misleading the public is a crime no matter what industry you are in. Extreme regulations in the financial advisor industry is a dis-service to the consumer.