Subject: File No. 4-606
From: Lee Ninneman

August 24, 2010

Misguided Fiduciary Standard on Registered Representatives

There is sufficient regulation already and I strongly oppose further regulation imposed on registered representatives.

I disagree that the fiduciary standard that is established for investment advisors has protected consumers better. Basically, the fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.

Lee Ninneman