Subject: File No. 4-606
From: Joel Willliamson

August 24, 2010

Requiring registered reps to meet fiduciary standards is UNNECESSARY and is a JOB KILLER. Fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.

The current methodology works well and has served the public well. These new standards would require extensive paperwork, extra staff time, and would ultimately inflate the cost of doing business which is paid by the consumer. Unfortunately, there will always be a minute percentage of advisors who will try to harm the customer no matter what regulations are applied and they will always figure a way around the rules.

Enforce what you have and do not add additional layers of bureaucacy to an already overloaded system. Remember, computers were supposed to become more efficient and save unneccesary conversion of timber to paper. Let's go GREEN and not enact more regulations that require more paperwork and unproductive time.

Thank you.