Comment from Stalnaker, JD, Charles, DIAL

Appointment of Entity - I support the proposed rule to permit claimants to appoint a business entity rather than one individual as their representative. This recognizes the realism of Social Security practice today, as it takes a firm or multiple persons to handle the volume of documentation, research and processing required to represent multiple claimants. Fee Payment and Direct Deposit - The demonstration project for non-attorneys is patently unfair and biased. I believe there is a potential constitutionality issue descriminating against non-attorneys. Just because an individual is an attorney does not mean they are more qualified to process claims or receive payments. By not allowing non-attorneys to receive direct payment, non-attorneys are being openly discouraged from providing representation. The criteria for certifying non- attorneys in the demonstration project is calculated specifically to protect attorney monopoly in Social Security representation. A new attorney or one not familiar with Social Security law and practice would be a less effective representative than a seasoned and experienced non-attorney. It is also NOT a good idea to require each person in a firm or organization that has performed representational services on the claim in question to qualify for direct payment, as many secretarial employees or legal assistants in firms could not formally meet such criteria despite years of Social Security claims experience. I do not support these proposed changes for fees and direct deposit and I do not support the demonstration project related thereto.