Subject: File No. 4-606
From: John O'Reilly

July 28, 2010

As an owner of an independent RIA, my greatest fear is that you will lower the RIA fiduciary standard.

My second greatest fear is that you will increase the other non-fiduciary entities to a fiduciary standard equal to a new lower RIA standard. Now I just lost my competitive edge and American people lose too.

People that want a high level of fiduciary care deserve it.

What I would like is for RIA's standards to be increased as well as everyone else. That way the American public wins and everyone else wins. Maybe the new higher RIA standard could be voluntary in case existing RIA feels this hurts them.

As a part of this, please outlaw the non-fiduciaries (or low level fiduciaries) from using titles and language to look like fiduciaries. The only financial advisors are IARs The 401(k) industry particularly is full of non-fiduciaries using the word "fiduciary" as often as they can. Many plan sponsors think they are receiving fiduciary care, and they are not.

SEC: Are you banning lunches/dinners/junkets with lobbyists right now? Hope so. So many good attempts in the past to clean this up have been foiled by lobbyists.