Subject: File No. 4-606
From: C. Richard Herrold, CFP

August 25, 2010

As an accredited investment fiduciary (AIF) and certified financial planner(CFP) I believe that I understand fiduciary standards. However, I am opposed to the demand that all financial service personnel be held to a fiduciary standard. For example, an investment banking project to finance a business expansion could not fit into the fiduciary realm. Rather, I believe that we should clarify our language and inform all investors as to the difference between fiduciary advisors and brokers. I have no trouble explaining the difference to clients, and adjusting my fee model to fit the activity.