Subject: File No. 4-606
From: David H Horan
Affiliation: Past President of Central New York Chapter of SFSP

August 16, 2010

I spend a great deal of time working with my clients on their financial needs and goals. I also monitor their performance and meet with them on a timely bases. The suitability standard we use tries to prevent harm to consumers through frequent FINRA and my broker-dealer suggested audits and compliance reviews.

I hold a series 7 and series 63 licenses and also hold an Investment Advisor designation. We spend several days a year in our broker-dealers annual conference on compliance and spend more hours online with additional courses for compliance. I want to spend more time with my clients not less. By adding additional compliance requirements and fiduciary standards we will be forced to spend less time on suitability, risk tolerance and other critical measurements of my clients goals. I estimate that I spend more time completing compliance forms and suitability questionnaires than I do with listening to my clients needs and goals. I want to spend more time with my clients, please help me do this and continue the high level of service I can now provide. Thank you for your time. David Horan CLU