Subject: File No. 4-606

August 9, 2010

To whom it may concern:

I have a difficult time understanding what purpose additional onerous compliance regulations will serve in protecting the public. My strong feeling is that it will only serve to regulate those of us who are honestly trying to comply out of the business because of the high cost of meeting the paperwork demands audits. It is already to the point that you cannot afford to serve a client unless he has at least 200K in investable assets. That leaves a lot of people left to their own devises to be properly served. Is that really protecting the public?

Perhaps my biggest concern is the liability attached to all of the regulations. There are now serval adds being run in the local papers by attorneys soliciting anyone who may have any disgruntlement with investment returns or other investment issues. You have already provided an environment that entices the legal community to attack what we do regardless of how hard we try to address suitability issues and document every move we make. It doesn't matter how innocent we may be, the cost to defend is enough to ruin your practice increase your EO costs. Is that really protecting the public?
I have 2 of my children that have expressed an interest in this business as a career. Knowing what I do of the compliance and liability issues, I have a hard time encouraging them to proceed and now you want to make it even more difficult. Is that really protecting the public when you make it so difficult for new people to enter the business?
You who make all of these rules and regulations have no idea what it is like to live under them and try to make a living. I challenge you to use some common sense in what you are promoting as there has to be a balance between regulation and the ability to comply or simply isn't worth the effort and liability. DOES THAT REALLY PROTECT THE PUBLIC??? I for one certainly don't think so