Subject: File No. 4-606
From: Dennis F Luebbering

August 25, 2010

I am opposed to the new SEC proposed Fiduciary Standard on Registered Representatives. I believe this is a misguided approach that is designed to punish representatives on a "look-back" basis, and is not designed to protect the consumer and keep them from making wrong investment choices for the future. Hind sight is always 20/20 vision. Anybody can report on what did not turn out as we all had hoped. Investment choices can be complex enough, and consumers do not need more paperwork to sign to confuse them even more. We need to have clear and concise focus as we invest in products, with easy to understand procedures for both the investment representatives as well as the consumer. By working together to achieve consumer goals, the consumer has a better chance of attaining his or her investment goals. Both the consumer and the investment representative need to have a clear understanding of where the client is today, and what they want to achieve for tomorrow. If this is clearly defined, this will eliminate much confusion in the market place today.

I am very much in agreement that we need to protect our clients, and this can be achieved via the standards of suitability that have already been established. I frankly believe if there are intentional injustices being done by the investment representative to the consumer, there are already laws in place to deal with these issues. We simply need to enforce the laws. I am aware there are problems in the industry, but let's enforce laws already on the books.