Subject: File No. 4-606
From: Kelsey Steuber

August 2, 2010

The current suitability standard for broker-dealers is a very robust and heavily enforced standard. It encourages broker-dealers and registered representatives to truly examine a clients needs and goals and determine what products and recommendations best fit their situation. The cost of implementing this type of change is high both in financial terms and time spent. These costs will be felt by our clients either by fees charged to them or a lesser amount of time given to them by companies and representatives. In the field, we are not given access to a crystal ball and we cannot predict the future. We have to make recommendations given the information we obtain from the client and our evaluation of their overall situtaion. Using that information, we then give our well-thought out recommendations for the product most suitable to their needs and wants. As their situation changes over time, we continue to meet and evaluate their products to make sure that each fits their current needs. We can only work with the information given to us at any given time. For that, I urge you to heavily consider the change you are proposing.