Subject: File No. 4-606
From: JAMES L McINNES

August 24, 2010

PLEASE DO NOT EXERCISE YOUR AUTHORITY TO IMPOSE A MISGUIDED FIDUCIARY STANDARD ON THE REPRESENTATIVES AND ALL BROKER-DEALERS. ANOTHER LAYER OF REGULATION MEANS MORE COMPLIANCE AND MORE COSTS TO ALL OF US - NOT ONLY FINANCIALLY BUT TIME INVOLVED.

THE SUITABILITY STANDARD GOVERNING BROKER-DEALERS AND REPRESENTATIVES IS WELL DEFINED WITHIN OUR LICENSES THAT WE HAVE EARNED AND MAINTAINED THROUGH CONTINUING EDUCATION.

WE ARE REMINDED CONSTANTLY OF THE INDUSTRY ETHICS REQUIREMENTS, THE CODES OF ETHICS OF OUR PROFESSIONAL ORGANIZATIONS, AND THE CODES OF OUR PROFESSIONAL DESIGNATIONS TO PROVIDE EXCELLENT SERVICE TO THE PUBLIC AND REMAIN IN COMPLIANCE WITH ALL OF THE EXISTING REGULATIONS