Subject: File Number 4-606

August 29, 2010

To Whom it May Concern:

I strongly believe that brokers and dealers should be treated as fiduciaries and be required to act in the best interest of their customers for the following reasons:
1.> The average person understands very little about the market and the various financial products available

2.> Hardly anyone realizes that there is a difference between brokers and dealers, as opposed to investment advisers

3.> It is unconscionable for anyone selling a financial product to sell based upon the expected commission. rather than the needs of the client.

I feel very strongly about this issue because:
1.> My father sold life insurance from the 1930's to the 1960's for one of the largest Life Insurance Companies. He always told me that his motive in selling insurance was to provide the product his client needed, not the product that gave him the best commission.

2.> I am an attorney with a solo practice. A large percentage of my clients are senior citizens. I have seen many instances where unscrupulous brokers and dealers have sold inappropriate insurance to people in their seventies and eighties.

I appreciate the opportunity to state my beliefs on this matter