Subject: File No. 4-606
From: David C Partheymuller
Affiliation: CFP, RIA

August 17, 2010

To whom this may concern

I am an RIA and an OSJ, have many clients and manage many millions of dollars. I am in this business for more than 25 years.

I can't believe that there is even a discussion regarding the adoption of the new fiduciary standard as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. If the consumer in question was your mother or father or some other loved one you would undoubtedly require it and so would any sensible and consciencious financial practioner.

I believe the need for this standard to be self evident and long overdue for the consumer's sake.

Thank you in advance for your consideration in regards to this important matter.

Dave Partheymuller, CFP
Normandy Capital Management, LLC A Registered Investment Advisor, Securites Offered Through Geneos Wealth Management, Inc. Member SIPC, FINRA