Subject: File No. 4-606
From: James E Astor

December 16, 2010

Financial Advisors, or Registered Representatives, as most of them are, need to be held to fiduciary standards and made accountable to the people whose money they invest. I have had several elderly friends taken in by these Registered Representatives, who blatantly misrepresent their true allegiance in order to sell products that will gain them the most profit, while typically costing the client much in excess fees or lost opportunities. Quite often I have seen churning of accounts and the sale of annuities to elderly persons who had no need of such a product. That very few of these Registered Representatives recognized the impending market crash, as evidenced by the dramatic fall in their clients portfolios, as well as their own, belies their claims to be financial advisors. In most cases they are skilled salespersons better trained in sales techniques than in market analysis. Having worked in banking for nearly 20 years, I was hearing recommendations to limit my financial exposure from several astute financial analysts while the majority of Registered Representatives were eagerly encouraging their clients to invest more into a "bull" market that had no end in sight. The warning signs were there and evident to those who were trained and skilled to recognize these signs. Unfortunately, too many are not. Even so, a trained, skilled person with a fiduciary responsibility would have analyzed the situation and encouraged their client to periodically rebalance a portfolio and not get overweighted in one sector.