Subject: File No. 4-606
From: Stephen O Rothschild, CLU, ChFC, CRC, RFC
Affiliation: President, Rothshild Sale

August 23, 2010

I am concerned regarding the new proposed Fiduciary Standard on Registered Representatives. I have operated in many states for over 40 years without a single complaint.

When you create rules based on the lowest common denominator (a registered representative acting improperly), you punish the vast majority of representatives and their broker dealers who are attempting to properly help and protect the buying public. Please enhance the penalties for the "bad registered representatives" and their broker dealers. I don't want them in my industry any more than you would.

With increased regulation comes increased costs. Those costs are passed on to the buying public or the registered representative or broker dealer or some combination. Smaller clients will not get the services they need as we can't afford to provide them the services they need. Some registered representatives will find another occupation and some small broker dealers will disappear. The buying public will be hurt and the small investor will disappear.

Why not have some exemption from the new rules for those who have 5 or more years of experience? How about no exemption for anyone who has ever had a prior problem even if they have been in the industry for years?

I could go on but I believe you understand the message I have written. Let's not create regulation for regulation's sake. Please be creative and NOT act like those who have created inappropriate regulation in other industries which you experience when you are the actual consumer.