Subject: File No. 4-606
From: Charles A Duff

August 7, 2010

I disagree that the judiciary standard offers better protection to consumers. The fact is excessive amounts of money will be used in lawsuits enforcing a backlog of retroactive breaches. This will slowly undermine all private financial insurance and investment institutions by changing the focus to lawsuits rather than frequent audits and compliance processes. I see the suitability standard of government as the cornerstone of Americas opportunity to build wealth. When the system is regulated properly with the tactics that are in place it is a solid form of consumer protection.

Charles A. Duff