Subject: File No. 4-606
From: Ben Caton

August 6, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced.
Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.

We are already highly regulated and a concern for our clients. More regulation will require increased cost which will be passed on to the clients

Thank you.