Subject: File No. 4-606
From: Kevin P Condon, Ph.D., CFP
Affiliation: EVP, Advisor Services Myfinancialadvice, Inc.

July 30, 2010

The provision of advice at a fiduciary standard is possible using the leverage of the web and phone. Modular advice sessions on retirement planning can be provided to all American workers through employer intranets and linked web service portals. Up until now, subsidy for the advice given to employees came from investment companies and insurance companies who provided the products. With the new law, definitions and subsidy should be provided that allows payment for the advice openly.

Advice sessions must be personal, data-informed and provided by competently trained and experienced advisors. The web will allow this now, multiplying the availability of advisors with technology and templatized advice formats. Please don't reduce the integrity of what will be called "fiduciary advice" by lowering the bar to help product companies protect their turf. Instead, encourage and subsidize the use of technology-equipped expert advice providers in all workplace deployments. See an example of how this works here:

Example advice sessions and a case study showing results using HSA advice, which can be coordinated, are attached.

(Attached File #1: 4606-230a.pdf) (Attached File #2: 4606-230b.pdf) (Attached File #3:4606-230c.pdf)