Subject: File No. 4-606
From: Diane L Moore, IAR

August 24, 2010

Requiring registered reps to meet fiduciary standards is UNNECESSARY and is a JOB KILLER. Fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.