Subject: File No. 4-606
From: John Gugliotta, Jr., Jr.
Affiliation: CPA CFP

August 17, 2010

Fiduciary needs to be the standard for everyone working in the financial services industry. I realize this goes against the interests of the brokerage industry, where production volume and product incentives exist. But a bias in favor of the Rep and their employer should not and cannot be allowed to exist while others in the industry are held to a higher standard. The hypocrisy must end

If a lower standard is going to continue to be allowed to exist, then a disclosure needs to be required that reads (in simple english) "the investor should be wary of who the Rep they are talking to, because the Rep can and will put their own and company interests ahead of the investor." If John Q. Public Citizen is going to be protected, then half-measures cannot be the solution to this problem.

A way of getting to a uniform standard is to change the compensation system to a percentage of assets under management. I realize even this standard isn't 100% pure but it's simple and straightforward. Maybe the percentage ought to be tiered based upon production levels but everyone should be playing the game by the same rules.

I'll close by asking you to remember that the point of this discussion is to determine a standard that is in the best interests of the public. There will be two components to it, determining that standard (which must apply to everyone in the industry) and the means of meeting it (which must also apply to everyone in the industry). Frankly, the system of compensation must change to get us there. Without it, I believe we are kidding ourselves that the standard will ever be met.

Thanks for listening and good luck - you'll need it should you decide to resist the sizeable pressure that will be brought to bear against you to compromise when setting the standard.