Subject: File No. 4-606
From: Barry A. McBride
Affiliation: NAIFA, SFSP, NAEPC

July 30, 2010

I strongly oppose the imposition of Fiduciary Standard on individuals supervised through Broker Dealers. Per the American Heritage Dictionary, Fiduciary means,"pertaining to, or involving one who holds something in trust for another", "pertaining to, denoting a trustee or trustee relationship." As investment advisors, we work hard to study and prepare to assist clients, but we do not hold their assets in trusts, nor do we manage their investments in the same way trustees do for the beneficiaries of trusts. This imposition would bring more regulation, more supervision, more unjustified costs, would drive up EO Insurance premiums, and would result in more costs passed on to the consumer, with no elevation in service. Please do not impose this.

Barry A. McBride