Subject: File No. 4-606
From: Elizabeth W Jetton, CFP(R)
Affiliation: Executive Faculty, California Lutheran University Sr. Advisor, RTD Financial Advisors Inc.

August 25, 2010

Thank you for taking seriously the regulation of investment and financial advice in an effort to serve the public's interest.

Over the past 30 years especially the clarity and distinction between bank services, brokerage services and RIA services have blurred. We now have a situation where individuals offering financial advice are regulated through two different bodies under unlevel and different standards. These differences ahve real consequences for clients. Quite simply, without a fiduciary standard that applies to ALL individuals providing advice, we have a situation where clients, without knowing it, are being advised by individuals who must put the interests of the employer (by law) ahead of the interests of the client.

There is a lot of fear within the financial services industry that this fiduciary standard will be unreasonably expensive and create the danger of a massive increase in lawsuits that expose the advisor and firms to huge liabilities. That is a fair concern but one that should not prevent making the right decision. This issue should be addressed by making clear the limits of advice within an economy and markets that are unpredictable.

The breach of trust that has occurred must be addressed and this will come about through the combination of more relevant regulation that is applied equally to anyone giving advice, regardless of how they are compensated or where they work and attention to oversight and adequate enforcement. No industry enjoys the burden of regulation but we in the profession of financial planning are asking for it We are asking for prudent and relevant and fair regulation that reflects the 21st century and our values.