Subject: File No. 4-606
From: Marylin Myers
Affiliation: President, Myers Associates Consulting LLC

August 3, 2010

Regarding the perception that the fiduciary duty governing investment advisers provides greater investor protection than the suitability standard governing broker-dealers:

I hold Series 6, Series 7, Series 63 and Series 24 Principals licenses as well as Life and Health Licenses. These licenses require annual compliance coursework, license fees, continuing educaiton, mandatory ethics and annuties training, and myriad other communications requirements.
I am required to be examined by our Compliance Department and supervisory personnel at least twice a year for FINRA and for Company Regulary Compliance. These appointments are comprehensive and lengthy as we reveiw files for sutiabiltiy and compliance to all regulation currently in place. These meetings are a minumum of 6 hours and require that all paperwork and correspondence with clients since the last visit be reviewed.
The issue is one of oversight of the actions of those at the top who are not meeting with clients on daily basis, and who are responsible for aberrant and non-judicial behavior.
We are on the front lines serving our clients. We have so many regulations in place now that we cannot even move without oversight.We are properly trained and consientious in our work and there will always be those who take advantage of any situation in which there is money to be made, but they are the exception.The rules that are in place are sufficient. The Government cannot legislate morality.
PLEASE DO NOT PUT THE FRONT LINE UNDER MORE RULES AND REGULATIONS. THIS IS NOT WHERE THE ISSUE OF WALL STREET CORRUPTION LIES.