Subject: File No. 4-606
From: Robert A. Pierce, CLU, ChFC, CFP, MSFS
Affiliation: NAIFA, SFSP

August 25, 2010

I have been a Registered Rep for nearly 40 years and have ChFC, CFP, MSFS and am Series 7,53,24 and 63 and have had a rewarding career both financially and satisfaction of helping clients.

The fiduciary standard is very troubling. As a Registered Rep for nearly 40 years, the potential unlimited liability for lawsuits based on hindsight is unfair. For example, the current market volatility could prevent clients from getting good investment counsel since a market dip could be reason for complaints or lawsuits. The wording appears so vague that interpretations could cause needless lawsuits or claims.

We have a good and fair method now that serves the public well. Regardless of your methods there will always be some crooks and your choice of regulation will not change the crooks but may needlessly punish the good Registered Reps and cost us additional staff and Administrative time and money.

Please do not implement a fiduciary standard on Broker/Dealers and Registered Reps.

Thank you for your consideration.

Robert A. Pierce