Subject: File No. 4-606
From: Robert H Johnson , III
Affiliation: Financial Advisor

August 2, 2010

I am writing to express my opposition to the consideration that the SEC may impose a fiduciary standard on broker dealers and their registered representatives. I am a Registered Representative and also an Investment Advisory Representative. My broker dealer is Park Ave. Securities, 7 Hanover Square, NY, NY 10004. I also an a licensed life, health insurance agent.

I have provided financial counsel, information, disclosure, and clarification to my clients for 25+ years.

The system under which I have worked with my clients is "the fiduciary standard". We meet and/or speak at least annually to review their financial progress, risk tolerance, goals, and concerns in light of the current economic situation as we look to their future together.

I am required to take many continuation education courses in order to keep my series 6, 63, life, health, variable annuity licenses/registrations active and current.
Some licenses require 24 hours of CE every 2 years, some require annual CE. Annual anti-money laundering courses are required for both life and investment licenses.

I believe moving to a fee-only system will hurt all of my "low income and middle income" families. I have many clients who are investing $200 to $300 per month in an IRA,Roth IRA, 529 plan or saving money in permanent life insurance, or who have little assets and are purchasing term insurance and paying off debt.

A fee-only model will not result in unbiased advice. Everyone has a bias.

A fee-only model will result in another layer of regulation which will result in another layer of compliance which will result in even more costs to clients.

Thank you for your consideration.

Robert H. Johnson III
W 614-785-5100 x202
C 740-815-7903
H 740-369-7783