Subject: File No. 4-606
From: Howard Pressman
Affiliation: Certified Financial Planner, Financial Planning Assoc.

August 18, 2010

I am a Certified Financial Planner(r) and an Investment Advisor Representative with over $20M in assets under management. I am commenting to express my opinion that holding all providers of financial advice to the same fiduciary standard will only help to better serve the consumer.

Now more than ever consumers need advice and guidance in planning for their futures. Defined Benefit plans have been replaced with Defined Contribuion plans, putting all of the resposibility on the individual to make the decisions necessary to insure their future. That is an awesome responsibility and one that average Americans are ill-prepared to handle. It is imperitive to their success that we do everything possible to create an environment of trust and clarity, one in which consumers know that when they are talking to a "financial professional", the person they are talking with has only their best interests in mind.

As a former employee of a large bank owned brokerage I was instructed to tell my clients when I was acting as an advisor with a fiduciary responsibility and when I was acting as an investment consultant with a suitability requirement. My clients no more understood this than I do quantum mechanics. If we are to protect clients from the unscrupulous advisors of the world, the first step should be to remove intentionaly confusing and misleading standards and replace them with a common standard of care that all consumers can understand.

As a practicing financial planner, my experience tells me that it is in the public's best interest to enact a fiduciary standard of care. In uncertain times, we should be doing all we can to help consumers make sense of an already complex financial maze, not allowing large corprorations to wiggle out of their responsibilty by confusing and misleading consumers.

Thank you,
Howard Pressman, CFP(r)