Subject: File No. 4-606
From: James E Ison
Affiliation: Registered Rep for First Allied Securities, Inc.

August 17, 2010

I believe a fiduciary standard for all professionals that provide financial advice and investment products (to include fixed products such as annuities and life insurance), not just investment professionals, would benefit consumers because they would be able to have a baseline level of trust that the advisor is supposed to be acting in the clients best interest. Strong enforcement of this rule will remove the unethical salesman (and force many more to change professions before being caught, censured, fined and/or jailed). Every month, I meet a new prospect who worked with a minimally licensed and rarely educated "professional" and am ashamed that in the prospects eyes, I do the same work as these salesmen. The only other option that would be acceptable to me is to have the clients sign a form (yes-more paperwork, I hate myself for suggesting this) that is very simple and says something to the effect of (for anyone who is not acting as a fiduciary): I understand that Representative/Agent's name is paid a commission to sell you products. He/She does not have to put my interests ahead of thier own, therefore the products being recommended may not be the best products for my needs. Client signs. Since this last part is not going to happen, the best way is to apply and enforce a fiduciary standard on all financial professionals and insurance agents.