Subject: File No. 4-606
From: Thomas Sokoloski

August 25, 2010

The fiduciary standard in essence adds a vague legal liability standard that looks back (sometimes after many years) and is enforced after the fact by the SEC or trial lawyers who have perfect vision in hindsight. We do not need another layer of rules that do nothing to protect the consumer. The suitability standard looks forward, in the best interest of the consumer.