Subject: File No. 4-606
From: Matthew R Claeys

July 28, 2010

I have been a dually registered representative for over 10 years now. One thing that has been constant since I started was clients not knowing the difference between brokers, RIAs, or insurance agents. They assume that the advice they get from their life insurance agent is the same as they get from their broker, and is the same they get from a RIA rep. One of the main reasons for the confusion is that everyone from a accountant to an insurance salesman can, and do use the title financial advisor. In the clients eyes, we are all the same. They don't understand that their insurance agent, is out to sell them insurance. It might or might not be suitable for them, but the insurance agent doesn't have a fiduciary responsibility to the client. Same thing with a broker. He has to make sure the investment is suitable, but that doesn't mean that he is acting in the best interest of the client. The there are actual financial advisors, such as myself, that do have to apply the fiduciary standard to all interactions with the client. As a Certified Financial Planner, I can tell you that everyone in the industry knows the difference between the industry professions, but I guarantee that the clients do not. I'm fine with brokers not having to adhere to the fiduciary standards, but then they need to have a correct title. They should be "Stock Brokers". Insurance agents should be "Insurance Agent". People who truely are financial advisors and adhere to a fiduciary standard can and should be the only ones allowed to use the title "Financial Advisor". It is time to start calling a spade a spade. If you deliver financial advice to a client, you should be held to a fiduciary standard, plane and simple.