Subject: File No. 4-606
From: William R Russell, II
Affiliation: Financial Associate

August 2, 2010

Dear Sirs: I am concerned over the possibility of adding a fiduciary responsibility to the relationship of clients to financial representatives.

This would address improper acts that had already occured. Our company now has suitabiliy programs in place that protect the client and make any sale to be in their best interest.

Instead of adding layers of administration to an already highly regulated industry why not look at the policies that successful and ethical companies have in place and work on the prevention of bad practice and then utilize the present laws to discipline those who abuse clients.