Subject: File No. 4-606
From: Robert S Johnson, CLU, ChFC
Affiliation: Registered Representative, Park Avenue Securities

August 16, 2010

I am opposed to the proposal that would give the SEC the direction to impose legal fiduciary standards on Broker Dealers and their representatives.

There is an inordinant amount of time, forms and audits under current rules. The consumer is well protected under the current suitability regulations. To increase this regulation would be an unwise use of the consumers, advisors and governments resources.