Subject: File No. 4-606
From: Gary Montgomery
Affiliation: President, Wealth Security LLC

July 28, 2010

My concern is the weakening of the fiduciary standard. It remains nearly humanly impossible to recieve variable compensation such as commissions from an employer and be a true fiduciary. Putting the client first will become a cliche when actions and activities enrich both the advisor and the employer of the advisor.

My recommendation is to clear brokers and agents from the financial advisor label. They are not providing unbiased advice and never will no matter what the laws read. Financial advisors should only include Fee only advisors as other compensation will automatically call to question the true fiduciary duty.

If it is broadened to include a larger group of financial professionals such as insurance sales people or stock sales people (brokers) then the standard will be weakened inorder to accomodate multiple compensation methods and easing the conflict of interest limitations.

We should not weaken and thus destroy the Fiduciary standard as it will simply increase the damage to the consumer. It is clear that an education and limitation is required but not broadening the standard to the point of unenforcable meaningless marketing phrase.