Subject: File No. 4-606
From: Jay C. McCluskey
Affiliation: MBA.Clu.,ChFC.MSFS.

August 24, 2010

Without some kind of concrete definition as to what "best standard" means you are simply creating more worthless and burdensome regulations which will do nothing to help the client or registered representative.This in fact will damage the marketplace as reps.will be ever more reluctant to suggest solutions fearing litigation.Consumers will be forced into paying more up front costs/fees which will discourage their taking action at all.