Subject: File No. 4-606
From: David M Dinn, MSFS

July 30, 2010

If investment adviser A, who charges a 1% fee and his clients 3 year net average annual yield has been 5%, learns that investment adviser B, who charges .75% fee and his clients 3 year net average annual yield has been 6% (and all else is equal) does investment adviser A have a fiduciary standard duty to tell his clients to transfer their business to investment adviser B?