Subject: File No. 4-606
From: MItchell R Owen
Affiliation: Financial Advisor, Eagle Strategies, LLC

July 30, 2010

It is too much to ask Registered Representatives to comply with the fiduciary standard proposed by the SEC. Many clients are only interested in a specific product or service and the Fiduciary Standard is impossible to handle when you are only reponsible for a small portion of a portfolio. In addition, it will raise the compliance costs of myself and my firm, as well as the cost of protection.

As a CFP and a registered representative, I am fully aware of the differece in standard that I must employ in my role as a Financial Planner and a Registered Representative. If I had to upohold that standard for all my Registered Representative transactions, it would be impossible and force me to not work with some lower net worth clients, because the cost of monitoring their accounts on a fee-only basis would be prohibitive to me and my firm. Thus they would be left without professional advice.

It has been my experience that even rules such as this will not stop unscrupulous providers in any field, especially the financial services field.

Over the past two years there have been countless stories about, so called, finacial advisors, who should have a had a fiduciary responsibility, such as Madoff and others, under the current loaw, who were able to steal from clients.

The SEC should spent their time enforcing current rules and regulations to catch crooks rather than put additional costs and burdens on law abiding and caring Registered Representives, who in my oinion, generally are trying to help clients succeed and have a win-win plan.