Subject: File No. 4-606
From: Thomas R Gearhart

August 2, 2010

To whom it may concern:

Having learned that the SEC is considering the impostiton of the fiduciary standard on anyone providing professional investment guidance, I must weigh in.

I have been in the financial wervices industry for nearly 33 years. I dilignetly work to provide my clients with the same guidance I would follow if in the same circumstances. I hold 3 seperate securities license. I work only from a brokerage platform that requires the suitability standard. I have strict oversight by my OSJ. Every letter I send to clients is approved and initialed by my Director of Compiance. Every written proposal requires approval. I am eximaned twice each year. My full time assistant is vigilant in keeping our compliance procedures and records in good order. These are only the highlights.

My compenation is commission. I establish long term relationships with my clients. I am paid LESS than what I would earn in fees. this saves my clients money in fees that they ould othersise be paying. I am paid just fine.

I wourk with middle class Americans. If I was forced into a fee only role, they would get no guidance because they would be unable to afford to pay the fees. My average investment client has less than $50,000 invested. But it is important to them, especially since liability and compliance costs would be forced up.

If this happens, I may be forced to abandon this part of my business. This rule would hurt average Americans.