Subject: File No. 4-606
From: Robert J. Ziner

August 27, 2010

I have been an investor for over 40 years and in years past had several brokers and supposed financial advisers recommend many investments for me that were "suitable" but in retrospect were certainly not in my best interest. The majority of their recommendations caused me to lose money while the broker earned a commission for both purchase and sale and probably other income for pushing products that the employer was emphasizing. I am primarily a long term investor and at heart am a fundamentalist. As such, when dealing with the broker I tended to minimize red flags in financial or other data in favor of strengths that the broker preached to me.

I no longer seek advice from brokers, although I still like to read the details of analyst reports on a company in which I am considering making an investment. I believe that anybody seeking advice from a broker or financial adviser should expect that the other party will always act in the best interest of the investor, but in reality it would be foolhardy to operate under this premise in today's environment. However, anything less is and will remain unacceptable. Therefore, if we can change the system and Wall Street's mindset, maybe the word of the broker or financial adviser can eventually earn the credibility it should have always carried.

I am submitting the above comments as they pertain to consumer level investors, not agents of other investment companies. I believe that investment banking companies and their investing staffs should be presumed to have sufficient sophistication to discount any advice they receive, as long as the advising party provides disclosure of any applicable conflicts of interest for the particular transaction. What constitutes a conflict of interest between sophisticated parties is not the purview of this request for comment, but I tend to think there are relatively few other than one party being the counterparty to the other's transaction, in which case knowledge of this status should be sufficient disclosure.