Subject: File No. 4-606
From: Donna T. Gebhart
Affiliation: Investment Advisor Representative

July 28, 2010

I think if you are giving investment advice, we should all be under the same rules. Either you are a fiduciary or you are not. Bottom line, the advice you give should always be in the best interest of the client, not the firm. Broker-Dealers should have to take responsibility for what they do and how they advise clients just like an RIA. If a firm makes a mistake, they should step up and make it whole for the client without an argument.