Subject: File No. 4-606
From: Jon Beyrer

August 17, 2010

A fiduciary standard should apply to all investment advice.
The current dual standard allows an adversarial relationship between brokers and the consumer, and in most consumers don't realize that there is an adversarial relationship.

The largest financial services organizations in the U.S. marketplace have managed to exempt themselves from the way that most companies do business. Instead of competing on quality, brand and price--as, say, the manufacturer of shoes, groceries, furniture or computers do--they have found ways to generate their profits based on incomplete information and the financial illiteracy of American consumers. The market meltdown and sales of junk products and revelations of ultra-sharp dealing and subsequent legislation all point to the conclusion that free markets function most effectively, safely and perhaps even profitably whenever the product and service providers strive to provide maximum value for the dollars they receive from the consuming public.

A fiduciary standard would codify this behavior in an industry that is unfortunately unfamiliar with its most basic concepts.