Subject: File No. 4-606
From: Timothy C allen
Affiliation: MM, CSA

August 1, 2010

Please stop the SEC from imposing a misguided fiduciary standard on Registered Representatives. The current suitability standard governing broker-dealers and registered reps is robust and heavily enforced. It also works on the front end, preventing decisions which are not in the best interest of clients.

On the other hand, the proposed fiduciary standard is applied at the back end, so it will certainly not result in better, unbiased advise. Many reps will be forced to a fee-only model to protect themselves from liability. This will eliminate clients who cannot afford to pay up front fees. It will also drive up errors and omissions coverage, and will force many broker dealers out of business as their liabilities become too great.