Subject: File No. 4-606
From: Stephen P Barnes, CFA, CFP
Affiliation: Shareholder - Barnes Investment Advisory, Inc.

August 17, 2010

Dear Ms. Murphy,

I have been working as a financial planner for 27 years and am writing in support of a client-first, fiduciary standard for all those who provide investment advice to consumers.

The current dual standard for investment advice is unnecessarily confusing and harmful to consumers. Consumers should not receive a different standard of care for the same type of advice just because it is delivered by a broker-dealer or insurance agent rather than an investment adviser or Certified Financial Planner professional. Investors deserve clear standards that place their interests first above all those who give them investment advice.

A properly enacted, consumer-friendly fiduciary standard need not prohibit commission-based compensation. . . nor should it. Likewise, fiduciary accountability will not decrease the availability of services to middle-class America. To the contrary, investment advice within the construct of a fiduciary standard will benefit consumers by ensuring they are informed of conflicts of interest and receieve advice that is in their best interests.

I implore you to recommend to Congress that it is necessary and appropriate in the public interest and for the protection of consumers to extend the fiduciary standard to broker-dealers who provide personalized investment advice, and to initiate a rulemaking to achieve this necessary consumer reform that is far too overdue.

Stephen P. Barnes, CFA, CFP