Subject: File No. 4-606
From: Stuart B Rodwell

August 27, 2010

I believe that if you charge for advice whether via asset based fee or per/hour, then the client has every reason to expect that you are operating as a fudiciary and you should be held to such standards. If you hold yourself out as giving advice, as wanting to work with a client in anything resembling a comprehensive on-going relationship, then you should also be held to a fudicary standard. The commission based compensation model may fall under either standard, depending on the nature of the relationship. The client (marketplace) will move/change if they feel that an advisor they wish to look to for advice is not putting their interests in first. A designation or title is not the issue, choice is.