Subject: File No. 4-606
From: Arthur K. Gruber, CLU

August 12, 2010

I would like to comment on the proposed fiduciary standard on Registered Representatives being considered. I am a registered representative holding Series 63,65 and Series 7. I solely operate my practice on a commission basis and provide service to clients without regard to the amount of money invested.
I am heavily regulated and scrutinized by my broker dealer, FINRA, SEC and subject to frequent compliance courses and meetings.
I must submit all correspondence to my broker dealer and must justify all purchase recommendations for suitability.
Virtually, every action I take is monitored and it is a laborious process to make sure that I am in "compliance" on all issues. It may be necessary but it is already time consuming and involves considerable time. If additional requirements are added that involve my actions being scrutinized and requiring more reporting on my part, it simply is not worth being involved in the sale of any investment products.
There is a need for public protection against spurious representations-which is already addressed by current regulations. However, the practical effect of discouraging
representatives to remain in this business and provide the necessary service to their clients is sure to be buttressed by additional regulation.
Arthur K. Gruber, CLU