Subject: File No. 4-606
From: Rick Louderbough
Affiliation: Series 6 commission based mutual fund broker

September 7, 2010

I'm a series 6 commission based broker for 23yrs and have always adhered to the Fiduciary Standard. We called it Invest your clients money as if it were your own. I do And I fully disclose my commissions to my clients. We are not allowed to charge any fees so our only long term income is 25 basis points in the 12b1 fee. Take that away and I'm finished as a broker.

It's the SEC and FINRA who are not living up to their Fiduciary Standards. Examples
1.Front Running. Can anyone imagine a system where large brokerage houses and others are allowed to see orders coming in and buying those securities contained in those orders before placing the order? This is so blatantly illegal yet SEC allows it. Shame on SEC This is how they protect investors?
2. In 2005 the SEC NASD made it clear that the vast majority of mutual fund investors who do not trade often are better served and save money with a commission based broker. I have many articles written about this in 2005.
What has happened since then The SEC has completely caved to the large brokerage houses and others and bashed the commission based broker to look like a crook. I have read some of the comments submitted. People are confused because of the lack of competent leadership by the SEC and FINRA. Shame again on SEC and FINRA for allowing such wholesale class bashing and allowing the elimination of the most honest group of brokers in the country. We don't participate in any of the fancy shenanagans on wall st, we can't sell stocks or derivitives or shady "investmet vehicles", just mutual funds. And my compliance officers contact me to make sure every sale I process is the right thing for my client. Every Time
This Fiduciary Standard is the smallest part of this argument. The SEC has hurt both the small investor and the small broker in so many ways, once again SHAME ON THE SEC for allowing these conditions to continue.
Further Rulemaking What a JOKE
United States leadership is incompetent on all levels and the SEC is the most horrific example.
When are you going to do the Right Thing?
Most Sincerely
Rick Louderbough