Subject: File No. 4-606
From: Warren W Updike
Affiliation: Financial Advisor(Series 7)-Retired

August 29, 2010

I don't pretend to understand the implications and ramifications of such changes but, it seems to me that brokerages could be negatively impacted and some clients who self-manage their portfolios may incur higher costs as a result, and not be better served.

I would prefer to see a clarification and distinction of titles with an information campaigh to inform the public of the differences between those with and without a fiduciary responsibility, and allow the investing public to decide.

In as much as independent advisors must use a brokerage for clearing most transactions, the cost of such information camgaign should be paid by brokerages. The campaign itself to be managed by the appropriate agency.