Subject: File No. 4-606
From: Richard J Pertzborn, JR

August 2, 2010

The regulatory and compliance environment is already overwelming.

Historically, prevention and education (suitability) are far more effective consumer safeguards than reactions to (fiduciary) the actions of a few misguided representatives.

I currently do not charge fees and provide a huge amount of financial advise pro-bono. In my view, with 35 years experience, I would gain by moving to a fee practice however, many individuals would not because of their resistance to fees. Thus, many people would go without advice and be less informed under a "fiduciary" model than under the current "suitability" standards.

Thank you for your consideration of this critically important issue.

Richard J. Pertzborn, JR