Subject: File No. 4-606
From: William t Ryan
Affiliation: CEO Ryan Financial Advisors Inc.

August 19, 2010

In every other recognized profession, practitioners are required to adhere to certain standards that benefits and protects the public. Unfortunately in the financial profession we are just coming to grips with the need to call a spade a spade.
Simply stated, anyone who holds himself or herself out as an advisor, planner, consultant or any other similar term should be required to adhere to fiduciary standards and be tested and regulated as a registered investment advisor representative. The reason is that the public assumes that to be the case. Anyone who does not want to adhere to those conditions should be required to clearly advertise themselves as a salesperson for their employer and use more traditional nomenclature such as registered representative, broker or some other clearly definable name. Clients should also be required to acknowledge that they have been explained the difference. In the case where the practitioner is both a registered rep and registered investment asvisor, the higher standard should apply.
For too long stock brokers and insurance agents, all full time employees of their firms have implied that they were objectively representing the client in a fair and impartial way while they were actually pushing their company's offerings and funds. Let's get this cleaned up clearly and quickly.