Subject: File No. 4-606
From: Robert Krupp
Affiliation: Financial Consultant

August 4, 2010

I am Series 7, Series 66 and life insurance licensed.

The suitability standard governing broker-dealers and registered representatives has been very effective in providing control over client transactions on a real-time basis. I am concerned about another layer of regulation would mean another layer of compliance and lead to more cost for clients. It seems the Fiduciary standard is very subjective and would lead to more lawsuits which would lead to higher O and E insurance costs. The higher costs of doing business will pass to consumers. It would also lead to people leaving the industry. Less options for consumers equates to higher costs.