Subject: File No. 4-606
From: Bob Gerber

August 26, 2010

-I am an indepented registered rep. for a mid-size broker dealer. I am also an investment advisor rep., plus I have been a long time board member (and past president) of my local NAIFA (National Assn. of Insurance and Financial Advisors) chapter and a life qualifying member of our industry's Million Dollar Round Table (MDRT).

We just completed our annual broker/dealer office inspection/annual audit yesterday. We try to practice the golden rule and do what is in the best interest for our clients. (If we didn't do this, we would not have been in business for over 20 years) Alot of our clients are middle class Americans who cannot afford to pay a fee for their financial services. I strongly feel that our industry is regulated enough and further regulation will only eventually drive up costs to broker/dealers and registered reps. that will ultimately have to be passed on to our clients. Those of us that are active in this profession work by multiple codes of ethics within our industry and continually keep up on the latest concepts, products, etc. via continuing education (C.E.) requirements, industry and company conventions and association meetings, etc.

In closing, please understand that this memo may not be the most eloquent, but it is written with conviction and from the heart. Please do not impose additional regulation where it is not needed and only passes a burden and cost that is ultimately bore by the averaqe American consumer.

Thank you.


Bob Gerber