Subject: File No. 4-606
From: William P Harmon, CPA/PFS, CFP
Affiliation: Partner, Fortenberry Ballard, PC

August 25, 2010

I have been in the financial services industry since 1989 and a series 7 licensee since 1995. I have previously been employed by a wirehouse and am currently an Investment Advisory Representive with a large broker/dealer network. As a practicing CPA and CFP, I have always considered the needs of my clients to be first and foremost when giving advice and making recommendations. As a licensed securities broker, I know from firsthand experience and observation that the commission-based business model does not lend itself well to the securities broker acting in the best interest of the client. As a practicing CPA, I have witnessed results, time and again, of broker recommended transactions that were made without regard for the client's best interest, even while being considered "suitable" for the client. It is past time to provide the investing public wih one simple and easily understood standard - that everyone who provides personalized investment advice will be required to act in the investor's best interest. I strongly encourage you to start the process of restoring faith and confidence in our financial markets and financial professionals by adopting this fiduciary standard.