Subject: File No. 4-606
From: Charles O Goodwin, Jr

August 10, 2010

I am very concerned regarding the proposal of placing a legal fiduciary standard on Broker Dealers and Registered Represenatives. I have been in the business with one firm for forty-four years, and hold a series 7, and 63 license. Our company has a strict compliance department, and provides constant compliance meetings to make sure that their representatives are always on top of the regulations and best practices. We have a full-time Operations Manager located in our office. My business is primarily in the employer markets, 401(k), etc. I have employer cases that have been with me since 1969. I've retained these cases by always doing what was in the best interest of my clients, and their employees. Even though I have never had an EO claim, in all of my forty-four years, I have seen my premium for this insurance increase tenfold over the past few years. What will that cost go to if these new liabilities are placed upon us? I would like to be able to continue serving my clients, however if these proposals go through, it will be difficult for me to stay in business.