Subject: File No. 4-606
From: William O'Brien, Ph.D., CFP
Affiliation: Associate Professor Emeritus, Merrick School of Business

August 30, 2010

Brokers are paid to sell products. Therefore, they have an obligation to do so to the best of their ability. They may also have the flexibility to concentrate their efforts on those products that pay them the most.

Investors seeking, and paying for, financial advice have a right to advice that meets the highest fiduciary standards.

Professionals who proffer advice ought not to be selling products and those who sell products ought not to be offering advice. There is a built-in conflict of interest when the two are mixed as is being brought to light in the medical profession.