Subject: File No. 4-606
From: Steven F. Wertime, Ph.D.
Affiliation: Financial Planning Association

July 29, 2010

The fiduciary standard should not be watered down or diluted by "harmonizing" it with any lesser standard of care. "Fiduciary" means putting clients' interests first, ahead of one's own (or anyone else's, other than the client's), pure and simple. This is the right and ethical course for a financial advisor to follow.

If a separate standard is adopted for those who only sell securities or other products, that is acceptable as long as it is clear that these individuals or firms cannot in any way or fashion call or advertise themselves as "advisors," "consultants," "wealth managers," or some other term misleading to the public. In this latter case, the words "sales only" should be prominently displayed in any advertising permitted.