Subject: File No. 4-606
From: Frederick A Van Den Abbeel
Affiliation: Executive Vice - President, Trade-PMR, Inc.

July 27, 2010

Thank you for the opportunity to submit a comment in regard to proposed rule on file number 4-606.

According to one legal dictionary, a Fiduciary is defined as: "An individual in whom another has placed the utmost trust and confidence to manage and protect property or money. The relationship wherein one person has an obligation to act for another's benefit."

I am in FULL SUPPORT of the investment community adhering to a higher standard. I believe consumers do not understand the differences between what is suitable and what is fiduciary. I support those involved in helping consumers achieve financial security by operating under the highest ethical standard possible. The investment industry should welcome this level of integrity with more than mere slogans and verbal promises. Other professions already operate under this standard, why not the entire investment community?

Second, I am opposed to any weakening of the current fiduciary standard as currently required by existing statutes. The investment industry should be reaching for higher ground, not lower.

Last, I am opposed to the notion that an Advisor can operate under one standard for one client transaction and then switch gears and operate under a different standard for another transaction for the same client. This is unduly confusing for the consumer.

If achieving a higher fiduciary standard of care is not possible in the investment industry, I would let firms choose which model they wish to operate under. Select either BROKER or as an INVESTMENT ADVISOR. This way, consumers can then start getting a grasp which type of firm they are working with and can make a more informed decision with whom they trust for their intimate financial affairs.

Thank - you.