Subject: File No. 4-606

August 17, 2010

As you review the financial havoc let loose upon society and especially the weakest members of society by a regime which touted deregulation and no need for enforcement of existing regulation and thus no accountability, learn from those mistakes. Impose one highly ethical standard of enforceable regulation upon those that would claim to be able to guide consumers in the selection of securities.

The existing system is so callously misleading and devoid of ethical merits that it is in need of a new and drastically different standard of conduct. Do not listen to the industry's self interested cries that they cannot adapt to a fiduciary standard of care. They are simply concerned that if you change the standard they will be forced to act as accountable professionals instead of salespeople whose primary interest is in the sale not the financial suitability of the sale.

The standard of care that should be adopted for all securities sales should be the same as ERISA originally indicated was necessary for advisors dealing with retirement plans. THE PRUDENT EXPERT standard is in the best interest of all. Make the industry change its bad sales practices. Let it earn its profit by forcing it to do the right thing for all involved in the placement of securities in any portfolio.

The image that has been touted and cultivated by the industry and projected into the public consciousness is that of the caring professional, full of competence and comitted to doing the right thing for the client. Now it should be adopted as the standard of care that the public should be given by regulation. The "exclusive benefit of the client" measured by what an expert in the field would do in the same circumstances is the only standard of care appropriate for all securities transactions. One standard undiluted applied and enforced to create professional accountability and disgorge long standing practices which foster boiler house mentalities throughout the industry.