Subject: File No. 4-606
From: David W Macbeth
Affiliation: Certified Trust and Financial Advisor

August 10, 2010

As a former trustee in banks, I love that fiduciary standard - for that context.

However, in the context of commissioned salespersons, the standard seems impossible. For example, no trustee can earn more than their published fee schedule. No trustee can personally benefit from the relationship besides its salary.

A successful, commissioned person cannot fit that model.

What is the difference? A trustee is regulated to the standard of one who not only holds discretionary authority to sell, hold, or buy assets, not only authority to decide whether to distribute or retain assets, the trustee also owns the assets on behalf of the beneficiary.

The basic securities/insurance model clearly lacks those ownership, compensation, and discretionary criteria that are essential for full-fledged fiduciaries/trustees for the protection of the beneficiary.

What you have now shines dramatically superior to what I heard about you thirty years ago. If you need change, increments can be tried and tested without causing upheavals and without waiting forever to take hold.