Subject: File No. 4-606
From: Angelo Giannosa
Affiliation: Financial Advisor

July 30, 2010

Creating a new fiduciary model is uneccissary. We are already regulated through FINRA and our BD, tested every 3 years and an annual firm element. Holding a series 6, 63, 7, 24, and 66 already puts me in a fiduciary roll without having to charge a fee for it all the time. Mom and pop investors want good recommendations, and do not need to be charged an on going fee like somoene with millions of dollars to invest. The requirements of documenting every phone call, client appointment and so on is burdensome enough. The increased liability will result in higher fees to my clients, or it's not worth it for me to assume the risk.