Subject: File No. 4-606
From: Tom Becker
Affiliation: CTFA

August 30, 2010

I worked 35 years in a bank trust department where the fiduciary duty was the utmost importance in our client relationships. Our company also owned a brokerage subsidiary. It was clear to me that clients who used both services could not distinguish which professional had to meet the higher fiduciary standard when offering advice. Accordingly, most times the brokerage clients ended up with investments that contained more risk and had higher fees than the client situation warranted due to their age and with due regard to their financial net worth. Brokers and Financial Planners need to regulated as fiduciaries too

I am less concerned about dealers and investment advisors being fiduciaries, if we define investment advisor as a company who offers investment advice on assets held for management for a percentage fee which is disclosed up front....and not a fee from the investment products sold to the client. On the other hand, if you define investment advisors as financial planners then they too need to be regulated as a fiduciary.