Subject: File No. 4-606
From: Carol L Royer, CFP, CFA

August 30, 2010

I support a fiduciary standard for all brokers, insurance agents, annuity salesmen, investment advisers and financial planners who sell financial products to the public.
I also think that just as RIA's are required to disclose all fees and conflicts of interest with ADV forms, all financial product providers should be required to disclose the actual amount or % of commissions, fees and trailing fees that would be received by their firms if the client purchases proposed financial products. I find that current product prospectuses disclose expenses and the impact of sales charges, but the actual amount paid to the brokerage or insurance firm is difficult to determine. It would be helpful for a client to know, for example, if sales commissions are paid to salesmen all at once - up front - rather than spread out over the life of the relationship. This would be a indication to a consumer of financial products of whether or not the salesman is interested in a 1 time transaction - OR has a stake in servicing the client for the long term.

Carol Lee Royer, CFP, CFA, CDFA