Subject: File No. 4-606
From: Robert J Wernecke

August 24, 2010

The best plan is to protect consumers with a reasonable amount of regulation. If the regulation becomes too much, the public will ulitmately pay the price. Current Suitability standard is working. A fiduciary duty would go far beyond what is needed or reasonable. And may well do more harm than good. I am currently subject to more than adequate supervision and regulations that are designed to protect the public. New regulations will not eliminate the crooks and will make business more expensive and burdensome for the majority of honest reps.

Bottom line: Suitability is working and a Fiduciary duty is too expensive and harmful for very limited benefits - some of which are takeaways.