Subject: File No. 4-606
From: Robert E Caldwell, CLU, ChFC

August 24, 2010

A new regulation holding broker dealers and registered reps to a fiduciary standard is NOT necessary. The suitability standard governing broker-dealers and registered reps is already heavily enforced. Adding another layer of accountability (and liability) for reps will only result in higher costs to the customer, and it will not provide any substantial improvement to the custoner in terms of the service or product they purchase.

I am already spending a significant amount of money (including hiring a person to audit my files and the files of reps in my office) to operate in a compliant manner. This misguided attempt at protecting the consumer is not going to be able to deliver on what it proposes to do.

I OPPOSE this effort to impose a fiduciary standard on broker-dealers and registered reps.


Eddie Caldwell, CLU, ChFC