Subject: File No. 4-606
From: Robert M Webb
Affiliation: Registered Rep

August 24, 2010

I do not think suitabiility standards should be changed to make all Registered Reps comply to additional fiduciary standards. Reps already do suitability to the point of overkill and additional paperwork will make them less efficient in looking after their clients best interest. If held to more strict laws and the inevitable paperwork, the reps will have to start charging fees to cover their time and added liability cost. This is not in the best interest of our clients. People already are confused by all the forms required and to add another layer will just add to that confusion. The problems occurring and that the press follows involves situations that already have sufficient legislation and remedies. These were not done at the enforcement level properly and therefore not caught. Those people are understaffed and adding new rules will add to their problem of looking for real problems. In summary,if current suitability and compliance regulations are done and audited properly, there is no need for further rules.