Subject: File No. 4-606

August 24, 2010

Dear SEC,
The fiduciary standard is neither helpful to customers nor fair to insurance producers.

Wasn't Bernie Madoff a 'fiduciary?' Bernstein?

As a Series 6 licensed rep, I already have multiple requirements regarding customer suitability, mandatory training, and severe penalties should I breach my obligations.

This new fiduciary requirement will only add to my administrative burden, make it harder to serve my customers.

Further, I have heard RIAs, my competitors in some way, claim they ALONE put their clients needs first. It is a LIE. Paying 2% in wrap fees, every year for some random mix of EFTs may be worse AND more expensive than putting a portion of funds in to an annuity.

This "Fiduciary' standard is a 'give-away' to trial lawyers and large RIAs. It does not help customers and you have NO DATA that shows that it does.

Please reject this new standard because it does not protect customers (Madoff, etc), is anti-competitive (RIAs want it to reduce competition) and is not required (the current system protects consumers and has NOT been a source of fraud).

Thank you for your time.
William M Burke