Subject: File No. 4-606
From: Melody S Merritt

July 30, 2010

We are regulated enough We need to be able to service our clients. Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients. Our goal is to help our clients build for their future, not to have to pay outrageous upfront costs for our advise. The fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.