Subject: File No. 4-606
From: Carlos Cabarcas

August 6, 2010

I have a Series 6 and 63. I must test every two years. The process for obtaining these licenses required an intense amount of studying. My actions, products written and applications are scruitinized by the broker/dealer I am associated with. I follow all the requirements expected of me including handing out prospectuses, completing risk analyses and making sure I explain the products in a very clear and simple way so clients understand the product strengths and risks before applying.

We attend a mandatory compliance meeting where we must arrive on time and remain alert during the entire course. I also have spontaneous visits from my compliance manger who will stop in to quiz me on processes and spot check my files and brochures for compliance matters.

Futhermore, nearly all my submitted applications are followed up by a phone call from someone from suitability or compliance to confirm why the product was selected and that I complied with all that must be explained/given to a customer. A mututal fund appointment takes at least 2 hours of time and I typically block out that much time so I can make sure I cover and explain everything and fill out the electronic application which also prompts me to cover everything that is required. Many of these applications have resulted after a second or third visit. That's four to six hours of reviewing their need

In my opinion, consumers are sufficiently protected with our existing system. While perhaps there are rare instances where registered reps may have acted out of self interest or gone around the system, the reality is that all investments involve risk. Consumers understand that when we complete an application. It is my opinion that those who are protesting are doing so they want to access money that from a time horizon perspective was not intended for short-term financial need or scared by the recent market performance and their portfolio performance. I do feel badly for those whose time horizon coincided with the economic downturn. As unfortunate as that is, investors know there is risk which can work for or against them.

In summary, let us regulate ourselves as we do currently. The process works Adding regulation ends up costing the consumer more anyway and I think there are enough fees being charges as it is. Plus: NO AMOUNT OF REGULATION WILL MAKE PEOPLE'S INVESTMENTS PERFORM ANY BETTER AND ISN'T THIS THE REAL PROBLEM--PEOPLE ARE UPSET BECAUSE THEY'RE INVESTMENTS ARE PERFORMING POORLY. HOW WILL ADDED REGULATION CHANGE THAT??