Subject: File No. 4-606
From: Johan L Gjenvick
Affiliation: Financial Representative

August 2, 2010

Fiduciary Standard on Registered Representatives is a concept that needs more thought. Consider this. A registered representative charges a fee to a client and then is paid a commission on top. Where as the current model is built for the registered rep to make the right recommendation the first time to keep the client a client for a lifetime. If the fiducary standard is made, then the rep is paid twice for hopefully the same recommendation.

Additionally, I work with average Americans (income). My clients could not afford to pay a fee in addition to a sales charge. These regulations are not helping they are hurting the average American needing to save.