Subject: File No. 4-606
From: Michael Bird
Affiliation: Financial Advisor, Principal Financial Group

August 25, 2010

As a Registered Investment Advisor I fully support continuing the suitability standard as it stands for broker-dealers. The current suitability standard protects customers from the danger of unsuitable sales, is a robust and heavily enforced standard, and the industry has a thorough understanding of its requirements. Changing the standard at this juncture adds a substantial amount of uncertainty to the sales process with little or no benefit to our customers.

Respectfully,

Michael Bird