Subject: File No. 4-606
From: Adam Mosbach
Affiliation: Managing Principal

September 3, 2010

All registered reps when giving investment advice to the public should be held to the highest standard (fiduciary standard). Any argument against this is foolish and self serving. The rep should always act for the client as an advocate in the marketplace and place the clients best interest first- end of story. BDs should no longer be able to push certain products (proprietary) over others and give reps monetary incentive to sell certain products over others. All advisors should held to the same standard.If this means certain companies will need to change their model so be it. Today , we need to regain the confidence of the consumer and this is definetily the right step in that direction.