Subject: File No. 4-606
From: Robert R Loesch

August 24, 2010

Fiduciary standards on registered representatives would add another compliance burden that is not needed due to already strict compliance regulations. As a registered rep for more than 20 years I have never had a compliance problem or complaint. I have although been regulated and regulated to the point where it is almost impossible to keep up with compliance issues. This has already greatly increased costs and the time required to do my business.

Put simply, a fiduciary requirement will lead me and many older reps to simply stop selling regulated products and leave the business.