Subject: File No. 4-606
From: Phil C Richards, CLU CFP
Affiliation: Adjunct Professor Emeritus, Carlson School

July 30, 2010

The fiduciary standard is bad for middle income Americans.
The resulting fee vs commission consequences will reduce the number of "agents" and "advisors" who are able to serve all but the very rich.
Bad policy with unintended consequences for those who most need advice