Subject: File No. 4-606
From: Bobbie D Munroe, CFP
Affiliation: Owner / Fraser Financial

August 18, 2010

Fiduciary Standard

You have been charged with "studying" the fiduciary standard and whether it should be applied to all who offer financial advice. The simple and obvious answer is "yes."

For over 10 years, I have been a financial advisor providing financial planning services and investment management. As a member of NAPFA and as an RIA, I have provided these services as a fiduciary. However, no organiztation, membership, or creditial is required to demand that I work in the "best interests of my clients." It is simply the right thing for me AND for everyone in this industry.

"Suitability" is a woefully inadequate standard. I could recount a number of horror stories of new clients who have walked in the door because some recommendation that was "suitable" (I don't even see how that standard was is just hard to challenge) created financial havoc in their portfolios: 1-the young couple who was advised to take out an annuity in April 2009 and put EVERYTHING into a inverse SP fund 2-the 35 year old with high risk tolerance that was sold an annuity for her ROTH IRA 3-the endless stream who come in from big brokerages with the same asset mix, primarily portfolios that hold nothing but large cap stocks (one has to wonder if the brokerage has an inventory in these stocks).

The Rand Study several years ago indicated that the public is totally confused over who / which advisor provides the high fiduciary standard of care. Most of them thought their brokers did. You and I know better. And I have to say that some of the people who sell questionable investments are good people who have received bad education and incentives from their employers. For there to be any real change, you are going to have to apply the fiduciary standard to everyone in this business. Only that wll create the desired behavior, only that will force large companies to do the right thing.

So as you contemplate your decision, do NOT be swayed by the arguements that will certainly be provided by those who benefit from the lack of a fiduciary standard. Rather provide the protection to the public that is so needed. Remember, that "public" includes your parents, your children, your friends.

My thanks in advance for your consideration.

Bobbie D Munroe CFP