Subject: File No. 4-606
From: William J Small, LUTCF
Affiliation: Financial advisor

July 30, 2010

Imposing a MISGUIDED FIDUCIARY STANDARD ON REGISTERED REPRESENTATIVES is just plain foolish and stupid. Throw out the few bad registered reps and do not punish honest hard working reps like myself, who has been helping the same clients for over 18 years. Our compliance is too costly time wise and too costly. Again throw out the bad apples.