Subject: File No. 4-606
From: Gwendolyn J. Tibbals

August 11, 2010

As a registered representative of a major broker-dealer, I am opposed to the idea of extending the scope of applying the fiduciary level of responsibility to our business transactions.

We use the suitability method, which is pro-active and constantly under review. That does a better job for the client and is enough paperwork for us.

What would the standards be and who would set them, were the fiduciary method be applied to, say variable life insurance? Ex: if least costly is a desirable factor, how and what would be done to satisfy that?

Please vote against such an idea.
Gwen Tibbals