Subject: File No. 4-606
From: Joseph J McCusker, Sr.
Affiliation: Managing Member, Celtic Consulting Services, Inc.

August 25, 2010

Brokers, as I understand the original purpose, are supposed to be order takers. They should not be giving advice or telling a client how to invest or what to buy/sell. Advice and recommendations are/should be restricted to advisors. When a broker is asked to give advice he should refer the question to an advisor. In today's computerized world the task of placing an order is relegated to a computer. The investor does not need a broker to execute a trade. Therefore, every human involved in the process who even speaks to an investor should be treated as an advice giver.

This is somewhat ofa departure from the 1940 Act but it is how the industry has evolved. As a Registered Investment Advisor I want a level playing field. The large firms give brokers fancy names that sound like the broker is something other than an order taker so the investor thinks they are dealing with someone qualified to give investment advice.

Worse than the broker/dealer issue is the insurance agent issue. If they sell a product that involves a security in any way shape or form then they should be held to the fiduciary standard. In my small practice I have had to unwind too many VUL policies sold to the wrong people. A 74 year old lady who just lost her husband should not have been sold a 25 year annuity with no life insurance supplement. The agent got a nice commission for fleecing a little old lady.

It is time to prevent these things from happening in the future.

Thank you for reading this.