Subject: File No. 4-606
From: Kenneth J Shepherd

August 16, 2010

The suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards.

Compliance with 'fiduciary standards' will drive many advisers out of the market and eliminate a valuable advisory resource to consumers, especially in middle- and lower-income markets.

This will cause additional risk of lawsuits involving registered representatives and will increase costs to consumers.

Forcing registered representative to fee-only compensation will not necessarily result in better, unbiased advice for the consumer.

The end result will give the consumer less support and only large expensive firms can afford to remain, leaving the middle and lower income with no one to help them.