Subject: File No. 4-606
From: Richard Frank, CFP
Affiliation: Director of Business Development at National Wealth Management, LLC

September 1, 2010

As a CERTIFIED FINANCIAL PLANNER professional, I feel it is unnecessary to apply the fiduciary standard on registered representatives. With 23 years of experience in financial services, I can say with confidence that consumers are confused by TITLES. There was a time when registered representatives used titles such as Account Executive. Somewhere along the line, they began to use the title Financial Advisor, when, in fact, they are selling, not advising. I believe consumers would be served much better if there were strict standards on the titles used by professionals that accurately convey professionals' roles. The only time the title Advisor/Adviser could be used should be in a fiduciary capacity. If professionals are in a sales position, that should be accurately conveyed in their titles as well.