Subject: File No. 4-606
From: Marshall W. Gifford

August 27, 2010

Expanding the fiduciary standard will do nothing to help people get better advice. It will raise cost of business enough to completely cut out all but the wealthiest people. As an advisor that focuses on helping people accumulate wealth and with 17 years of experience, the legislation would force me to switch all clients to a fee based model but only accounts that are large enough to meet platform minimums. Most being $50,000 - $100,000. This would increase my revenue enough to cut loose the smaller accounts. So the lower net worth would go from receiving excellent advice already to no advice. This part of the bill is misguided and needs to removed for the greater good. Americans need to save, they need quality advice and this will move us further from that, not closer.