Subject: File No. 4-606
From: Chuck Epstein

August 31, 2010

Investment advisers and brokers should be held to fiduciary standards because the current load-fund business model is based on a conflict of interest. Due to revenue sharing and complex fee structures offered by fund companies, this makes the client-broker relationship overwhelmingly adversarial and all too often unethical. Specifically, revenue sharing makes it impossible to offer clients objective advice. In the case of some fund companies, brokers made more from revenue sharing than shareholders did in their acccounts. This is a hard dollar cost to uninformed shareholders, which makes it more difficult for sharholders to enjoy a financially secure retirement. In conclusion, adopting a fiduciary standard will make the mutual fund industry less commoditized, more competitive, increase ethical standards, and help restore confidence in financial markets.