Subject: File No. 4-606
From: Jeffrey M Orth, ChFC, CASL

August 24, 2010

It is important to maintain and continue to improve the Suitability Standard for client care. This is a leaning forward process that keeps the client and the reg. rep. working together for the clients best interest.

The Fiduciary Standard lacks the proactivity of the Suitability Standard. The Fiduciary Standard reacts to real and percieved problems in the past. In contrast the the whole point of the Suitability standard is to prevent problems in the first place.

I therefore urge you to stick with and help to continue to improve the Suitability Standard.

Yours to count on,

Jeffrey M Orth, ChFC, CASL