Subject: File No. 4-606
From: Subir Grewal
Affiliation: Principal, Washington Square Capital Management

August 24, 2010

I would encourage the SEC to consider extending the fiduciary standard to all persons dealing with the investing public and providing any form of investment advice or guidance in an individual setting.

The conflicts of interest generated by broker-dealers serving two masters are too thorny for individuals to navigate, especially when their own compensation depends on proceeds from the transaction at hand. Informational disparities between investors and brokers too often allow brokers to deliver self-serving recommendations or build in egregious commissions without disclosing them clearly.

Clients have the perfectly reasonable expectation that their advisor or broker will act in their interest. That expectation should be reflected in the law if advice is provided in an individual context.

The investing public our industry serves is not benefited in any way by convoluted exceptions for specific entrenched entities and different rules depending on an individual's registration. The sooner the standards are clarified, the better it would be.