Subject: File No. 4-606
From: Brian D Lipinski

August 24, 2010

Please do not implement the proposed fiduciary standard on BD's/Registered Reps. It is not reasonable to expect RR's to act with no regard whatsoever to their financial interest. It is also not wise to force customers to pay up-front fees for advice-many consumers will not pay the fee and will suffer financially as a result.

The vague liability standard is also problematic. If the regulators don't back off, there will be few, if any, BD's left to regulate