Subject: File No. 4-606
From: John Andrighetti, LTC (R)
Affiliation: Retired Army Officer and Operations Research Analyst

August 29, 2010

While I am sure brokers are ethical persons, the lack of a fiduciary standard has caused me to totally avoid brokers since 1988 when I began helping my new spouse manage her portfolio. While her broker's recommendations were generally good performers, we were not pleased once we compared the various costs, fees and loads associated with the broker's picks against other investments. Within a year, all but one of the broker's picks had been reinvested elsewhere.

We have met with other, non-fee "investment advisors" since 1988. With our backgrounds in Operations Research Analysis and the Legal System, we were able to evaluate their presentations and uniformly found them hard-to-understand and, once we spent the time to analyze their proposal, not to our advantage. Unfortunately, many people do not have the background and cannot afford the advice necessary to perform such an evaluation.

We cannot comprehend how anyone without an axe to grind would be in favor of not holding brokers to fiduciary standards. We certainly support holding brokers to the same standards as a real, for-fee investment advisor and, if they ever are, we would reconsider seeking their advice.