Subject: File No. 4-606
From: allen swartz, CLU ChFC

August 16, 2010

I took a CLU pledge more than 30 years ago to "put the customer first" ahead of myself, my employer, my suppliers, whoever. Regardless of the advisor's other relationships the fundamental allegiance to the customer trumps everything else. This eventually drove me to terminate my employment as an agent of a company and do business as an independent broker. One cannot serve two masters. I have no idea how you are going to resolve the issue faced by company agents or registered reps who must align themselves with one broker-dealer but I urge you NOT to sacrifice a principle that I consider a bedrock of our industry: the customer comes first, period.