Subject: File No. 4-606
From: Raymond Glathorn
Affiliation: retired

July 28, 2010

The current situation can be very misleading to people not exposed to the nomenclature currently used. Many brokers title themselves financial advisors or financial consultants when they are simply stockbrokers. Lets face it, a financial advisor title implies a professional whose obligations are fiduciary like a doctor or lawyer. On the other hand, the title of stockbroker indicates to a consumer that they have to be on their guard, ie like dealing with a car salesman. Hence I say if an individual is not acting in a fiduciary capacity the title should be "stockbroker" and no other designation should be allowed. I think anyone dealing with the uninformed and inexperienced public shoud act as a fiduciary but I doubt the big brokerage houses would let that happen. Therefore the public can be warned that the title stockbroker incicates buyer beware, you are dealing with someone whose interests may not be the same as yours. I also believe that any transaction with a stockbroker should require a signed disclosure agreement between the stockbroker and the transactee.