Subject: File No. 4-606
From: James Greco

July 30, 2010

I am adamantly opposed to the fiduciary standard being considered for Broker Dealers. After 25 years of serving the best interests of my clients, I don't need another compliance nightmare (fiduciary standard) to deal with. It's already a business where compensation does not adequately cover the liability that I face in every client dealing involving insurance and or investments. Whose objective judgment will define what is in the best interest of a client"? What is "best " anyway? Is it the cheapest or what's best in "long term", or "short term"? Or is it the company with best rating? There is no objective standard because there actually can't be... nothing is one size fits all. What's true for someone today, may be quite different for that same person 6 months from now. Am I now to be legally accountable for when client changes their mind about what "best" is for them in the future or what a regulator thinks two years later what was best for the client (with the benefit of 100% hindsight)?.
You might be surprised but I engage everyday in providing for the best interests of my clients as they represent it to me "at the time". Yes, even without all this government mind numbing compliance and regulation. Tbe suitability standard is more than sufficient for insuring the public is appropriately served. Creating a fiduciary standard will make my business no longer worth the liability that I would be subjecting my family to by having to operate under such an arbitrary standard.


James Greco