Subject: File No. 4-606
From: David S Alexander

August 18, 2010

I've been in the investment advisory business for the past 13 years under both the suitability standard as a broker and a fiduciary standard as a financial planner and trust officer. I believe that a uniform fiduciary standard should be established and applied to all professionals delivering investment advice to investors.

The simple fact is that investment advice is never "incidential" to the purchase or sale of an investment product. From the perspective of the buyer, the decision to purchase a financial product from a investment professional (broker, insurance agent, financial planner) is largely dependent on the advice and recommendations that the investment professional delivers to the buyer. In today's world, if the buyer really just wants a transaction with no advice, then the buyer will typically go "online" and make the transaction.

From the perspective of the financial institutions that sell products and services, most of the these firms acknowlege that the quality of the investment advice is a major factor of the investor's decision making process. This is evidenced by the resources that firms spend on investment research, hiring professional credentialed employees to support their sales force, and marketing material to portray the firm's insight and expertise in investment selection and planning. Many companies that specialize in online transactions provide "online" research advice in the form of reports or filters as a value added way to differentiate their services.

Clearly, investment advice is an important part of why investors choose an individual advisor or investment firm. Establishing a clear fiduciary standard for all who provide investment advice firmly places the investor's interest as the top priority. This is good for business and the investing public.