Subject: File No. 4-606
From: J C Otterbein
Affiliation: Registered Representative

August 9, 2010

The Current system of Suitability goverened by Broker Dealers is working. I have been in business 30 years. We are monitored very closely in the broker dealer system. It prevents client misunderstandings. We have not had any isses at our firm and we disclose everything to our BD.

Unproductive Lawsuits and unnessary regulation is not needed. It would only increase client and compliance costs.

Thank you.