Subject: File No. 4-606
From: Blake T Todd
Affiliation: Partner - Crowell Weedon Co

July 28, 2010

Definitions are important for all in the industry to be able to conduct themselves properly. Knowing what a "Fiduciary" is and what thier roles and responsibilities are is at the heart of the successful advisor relationship. I for one welcome the guidance and standards that will come from this process.

I know as an advisor I can only work with the information that is supplied to me by my clients. If that information is incomplete or misrepresented to me, it is still the basis of any recommendations that I may make. So I feel it is important that the client bear the responsibility of fully informing the adviosr of their true situation, and if not, the advisor only be held responsible for the recommendations based on the information they were provided.

Many clients do not want to relinquish responsibility for the risk to thier representative. They want the representative to carry out their instructions even if contrary to that representative's vision. I feel there should be some allowance for the public who want to make their own choices and take on the full weight of their own fiduaciary responsibility. Some way that the finacical representative who is acting as a facilitaor can be exempted from a fiduaciary responsibility they are not taking.

As an extension, the public should have an opportunity to select investment styles and methods that they feel are appropriate for themselves. If an investment style is well disclosed and selected by the client, then the client should be considered responsible for the appropriateness of that style within thier own total fianancial plan. As long as the advisor stays true to their stated style and disciplines they should be okay. And if those styles happen to not perform as well as other styles, then that is up to the client to determine if their allocation to that style continues to be justified. But the advisor should not be held liable for losses because his stated style did not perform well.

Many in the public need the advise and counsel of financial professionals. They do not have the education, time, or experience to manage their investments on their own. Financial professionals can influence the fiscal health of their clients just as a doctor can impact the clients physical health. As such those financial adviors should be required to maintain their knowledge and skill levels and obtain regular continuing education. In addition, they should have the potential of receiving fair compensation for the specialized education and experience they have obtained. And compensation, as with other industries, that is not limited by regulation.