Subject: File No. 4-606
From: Gerald R Kuhlmann

August 12, 2010

I am an RR and am commenting on new legal fiduciary duty being talked about for broker-dealers and RR's. Suitability standards are already stringent and heavily enforced and provide strong and appropriate consumer safeguards. If enforced, this will drive many advisors out of the market and take away a valuable advisory resource to consumers. It will increase costs to consumers due to additional risk of lawsuits
involving RR's. Fee-only compensation will not necessarily result in better, unbiassed advice for the consumer.