Subject: File No. 4-606
From: William R McNabola, PhD
Affiliation: Registered Representative, IAR, NAIFA

August 24, 2010

I believe that the expanded requirements proposed in the legislation for fudiciary responsibility is inappropriate and excessive for all financial representatives. A fully qualified Financial Advisor can charge fees for his advisory services by which he can pass the extra costs of maintaining compliance supervision on to the consumer. I cannot do this do to my firm's internal policy. How am I to be able to provide service when I cannot cover these costs? If there is any thought that additional regulation will save consumer's money think again. I tried for a time to operate as an independent investment adviser, and found the existing compliance burdensome to the point that I could not see my way clear to covering the costs long enough to build up my business--and this was with the old regulations.

What I really think, based on disclosures of the Madoff fraud, is that the SEC itself failed in the most rudimentary way to audit Madoff operations. Any one with a handful of falsified trading slips and their SEC credentials could have called the exchanges and discovered the fraud years before it was finally uncovered.

Instead of really examining what is wrong, it is easier to assume everyone is a crook and plaster over more regulation in a kind of random lashing out.

Let's do the investigations that you are enpowered to do and institute appropriate audit procedures that actually will prevent a repeat of this in the places where the misrepresentations actually took place.

Yours Sincerely,

William T. McNabola