Subject: File No. 4-606
From: Paul H. Rhodes

July 30, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. An example of this is, as a registered representative I have to attend training directed to and created for the purpose of maintaining appropriate communications and investing standards for Clients. This training is provided by the broker-dealer I am affiliated with. In addition, the broker-dealer monitors my actions and business to ensure compliance with FINRA rules. This is done effeciently and effectively without another costly bureaucratic, tax funded entity and it's employees.

In addition, I provide services to Clients without charging fees from the Client. My practice after 22 years in this business has proven that this arrangement has kept the Clients cost/fees associated with their business at a minimum and advice offered to our Clients is unbiased.

The current standard is applied in the real world with real rules and without vague, unenforceable rules that may look good on paper but cannot work in real life.