Subject: File Number 4-606

August 29, 2010

I would like to comment on the new rules you are considering.

I have been in the financial services business for over 25 years as both an employee and customer. Years ago, I was pretty sure who I was dealing with based on their titles. Account Executives and stockbrokers worked for broker/dealers and charged or earned commissions based on transactions in securities such as stocks, bonds, mutual funds and options. Insurance agents were responsible for selling life and health insurance. I knew they earned commissions on the policies they sold and they usually sold proprietary products. Bankers helped me with my savings and checking accounts as well as provided me with various types of loans including credit cards. Financial planners offered me financial advice and usually charged me a fee or a combination of fees and commissions.

Today itís a totally different story. All kinds of products such as securities, insurance, fee based products, bank accounts, loans, health insurance, auto/homeowners insurance, etc. are sold by people calling themselves:

Financial Advisors
Financial Consultants
Investment Advisors
Investment Consultants
Financial Planners
Asset Managers
Financial Services Advisors
Registered Representatives

These people are offering financial advice, earning commissions, charging fees and work for broker/dealers, banks, insurance companies and independent companies. It has come to the point that I really donít know who Iím dealing with. Even with my experience, Iím confused, so I can imagine how confusing it must be for novice investors or the general public.

I strongly support any rule that would require that people who provide financial and insurance advice and/or products be subject to the fiduciary standard. That way, I wouldnít have to figure out what their titles mean and who Iím dealing with to the extent that I would know they are required to work in my best interest and disclose to me how they are compensated and any conflicts of interest they may have. The broker/dealers would probably be strongly against this type of rule, but their own actions have led us to this point. They place their brokers in direct conflict with their clients by paying them commissions based on transactions, selling only proprietary products and incenting their brokers to do that. They also provided ďadviceĒ that would result in more, not less, transactions from their clients. Now banks and insurance companies are doing the same thing.

Itís time the pendulum swung back to the consumer.

Thank you.

Bert Oshiro