Subject: File No. 4-606
From: John W Farlow, CFP
Affiliation: Financial Abundance, LLC

August 19, 2010

As a Certified Financial Planner providing fee only planning services and an RIA providing fee only asset management, I am required to be a fiduciary in ALL of my activities.

If I was not required to do so, I would still place my client's interest before my own. This is the right thing to do for both my client's and my practice.

Other than the billions of dollars in commissioned products sales that are threatened, and the lobbying dollars that follow these commissions, there can be no benefit to the consumer to have broker-dealers and insurance agents held to a standard that does not put their client's interest first.

The argument that without commission sales, the consumer would have no one to help is absolutely ridiculous. As consumers have many sources for help in completing their taxes, without someone selling them a commissioned based product, consumers have the same plethora of choices for non commissioned investment products and advice.

The decision on whether to implement an across the board fiduciary standard will ultimately show whether the SEC wants to support broker/dealers and insurance companies or wishes to support the consumer.

I certainly hope that the consumer's interests are put in front of the lobbyists.