Subject: File No. 4-606
From: Marcia p Friedman
Affiliation: COO

August 24, 2010

You are so out of touch with what we do with clients. Please do not impose additional regulation that will increase costs to clients and burden us with regulations that are duplicative and not necessary. Current regulation provides the ability to look back and ensure the clients best interests are taken into account and the suitability of investments seriously considered.