Subject: File No. 4-606
From: Dan Campana, CPA

August 10, 2010

it is obvious that the SEC seeks to impose a misguided fiduciary standard here. 99% of all advisors are already acting in the "best interest" of their clients. furthermore this Act does not define what the rules are for compliance with a legal "best interest" standard - thus subjecting registered representatives to the potential of never ending lawsuits. this will only make it more costly for the consumer as well as increase headache and paperwork for the advisor and we may see many good ethical advisor leaving the industry due to higher cost for operating expenses as well as higher cost for EO insurance. this proposed SEC fiduciary standard adds a vague legal liability standard that looks back (sometimes after many years) and is enforced after the fact by the SEC or trial lawyers who have perfect vision in hindsight. please, please, please do not add more regulations on an industry that is already overly regulated...