Subject: File No. 4-606
From: Brian R Emswiler

August 24, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced.

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 office spends hours each month on compliance issue for our clients.

Making it tougher to help our clients is going to cost the United States and deteriate a profesional industry that already has high standards.