Subject: File No. 4-606
From: Richard A. Ray
Affiliation: SVP, Hamilton Capital Management

August 25, 2010

I am a practicing CFP, and very much believe in the Fiduciary Standard that is intergral to our CFP certification. My current firm, Hamilton Capital Management is a fee only financial planning and investment advisory firm. My prior work experience included Trust management with major banks like JPMorgan Chase, but also supervision of Registered Reps affiliated with respective Broker Dealers.

The duty of care as an RIA with a fee only firm like ours is clearly superior and in the best interest of clients. Bank trust departments also maintain an acceptable fiduciary standard. Unfortunately, many Registered Representatives, while technically compliant, operate far from the fidciary standards that are appropriate for clients bests interests.

I encourage you to adopt a universal fiduciary standard.
Richard A. Ray, MBA, CFP