Subject: File No. 4-606
From: Edward D Hinds, III
Affiliation: Financial Planning Association, Society of Financial Services Professionals

July 28, 2010

I believe that extending the fiduciary standard to broker-dealers is not ethically possible. Broker-dealers sometimes work with both parties in a transaction, such as when taking a company public. How would it be determined who deserved the fiduciary obligation?
I believe that there should be a definite program of making clear when a person enters into a commercial transaction, such as with a broker-dealer and registered representative and when a person enters into a professional program such as with a RIA where a fiduciary obligation holds.