Subject: File No. 4-606
From: Joanne S Madar

August 1, 2010

I believe that adding another layer of regulation on securities will not stop the abuse of the few persons in the financial services industry who have abused the trust of their clients. It will only cost the clients more money because many registered representatives will be forced to go to a fee-based model based on added liability and will pass that added cost onto the clients. The honest majority of financial service professionals are so heavily regulated now that most registered representatives and broker-dealers spend 25 to 35% of their time and their staff's time currently on compliance visits, approval on letters and information given to clients, constant testing, hours of classroom time and extensive detailed record keeping of all oral and written correspondence with clients. If you add to that they will have less time to spend with their clients and some will be forced out of the business because it will not be cost effective due to the additional liabilities that a fudiciary responsibility creates(errors and ommisions insurance will increase and fee-based advice will stop the average client from getting financial guidance). Unfortunately, it will not stop the few dishonest broker-dealers or registered representatives because they will ignore or find a loophole to the added regulation as they have in the past. However it will hinder or stop the average main street American client from getting honest financial advice that they need because of the added cost due to this additional regulation.