Subject: File No. 4-606
From: John Souther

August 24, 2010

The Sec should adopt a fiduciary standard across the entire financial industry where someone is advising or recommending a product or service or providing advice for a fee. Why would any investor want someone advising them who doesn't put their interests first and doesn't disclose all conflicts? It is possible to still have transactional business under a fiduciary standard, all conflicts just need to be disclosed and understood by the client. If the financial industry wants to be viewed as a professional industry, then it needs to be held to the highest standard. You do not want your doctor or your lawyer having a level of advice that may not be in your best interest. The same should be true for the financial industry.

The SEC should also not let portions of the financial industry try to water down the fiduciary standard. The 1940 act has served advisory investors well should be expanded to include everyone.