Subject: File No. 4-606
From: Jerry R. Neill, CLU, ChFC, CFP

August 16, 2010

To the SEC,

I spent 41 years in the financial Services profession, first in the life insurance business for 21 years and then 20 years as the owner of Neill Assoc., a fee only financial planning and investment management firm. We were Registered Investment Advisors and had fiduciary responsibility. Prior to forming Neill Assoc.,I was a life insurance agent and registered representive for securities on a commission basis.

While agents and brokers generally try to put the clients interest first, there is an inherent conflict of interest. When a large commission is involved, it is very difficult to be objective.

Therefore, based on my 41 years of experience on both sides of the issue, I absolutely believe all brokers should be subject to the Fiduciary rules. It is the only fair way to help protect the consumer in this very complicate financial world we now live in.

Jerry R. Neill