Subject: File No. 4-606
From: Randall G Vincent
Affiliation: Stonebrook Capital Management, Inc

May 15, 2013

The imposition of rules based compliance currently applied to the major broker dealers would if applied to investment advisors be very costly for small firms and would probably force many firms out of business. Having worked for a number of wire houses previously I know that the fundamental problem in our industry is conflict of interest, a problem that is minimal in investment advisors unaffiliated with underwriting securities firms. So in effect the expansion of regulations on investment advisors would have avery negative impact on our industry and would porvide little or no offsetting benefit. My firm has grown over the last ten years and has created 4 jobs, but if we get the harminization of the wire house rules applied to us it will have a very chilling effect on our future expansion plans. I think many firms would be affected similarly. In my opinion expanded enforcement of existing regulations on investment advisors is the best way to go.