Subject: File No. 4-606
From: John MacDougall
Affiliation: First Command Financial Planning

August 25, 2010

As a 20+ year professional adviser I believe it is actually important to retain two standards. It is is impractical to establish fiduciary care of a client without both full disclosure, analysis and a discussion of goals,health and anticipated family developments. There is also room for a rapid assessment of suitability for a particular investment situation AS LONG AS A CLIENT IS FULLY AWARE of the standard being applied in the advice offered. So what is truly critical is the clear delineation of the difference between two different standards being presented to,and accepted by the client during each interaction BEFORE a transaction is authorized, captured by a recorded device or electronic media for the record.This acceptance should be for that day(OR A DEFINED PERIOD LESS THAN 30 DAYS-as determined by future legislation) only for the less severe standard i.e. must be re-presented as an accepted choice for each transaction beyond that frequency.