Subject: File No. 4-606
From: Philip K. Selden
Affiliation: Chief Compliance Officer, United Advisors LLC

August 25, 2010

First, let me emphasize that I think that the vast majority of stock brokers and insurance agents adhere to the suitability standard that they are required to uphold with their clients. The more important issue is, however, the extent to which the suitability standard adequately protects the investor.

Since 1985, I have been involved with a firm that has been a registered investment advisor, first with the SEC, then with the state of Ohio, and then back with the SEC. As a registered investment advisor, we have always had a fiduciary relationship with our clients. We were - and still are - required to always put our clients interests ahead of our own on all of our recommendations.

If congress is really interested in looking out for the best interests of the investing public, then there is no question that the same fiduciary standard should apply to registered representatives as apply to registered investment advisors. I personally believe that insurance agents should also be required to be fiduciaries, but I realize that this is a state regulated question and not under the purview of the SEC.

In closing, I strongly support making the standards the same for registered representatives and registered investment advisors. Require both to have a fiduciary relationship with their clients, rather than keeping the current two-standard system. This can only result in higher levels of investor protection and therefore greater investor confidence.

Thank you for your attention to this matter.

Philip K. Selden