Subject: File No. 4-606
From: John C Girvin, CFP

July 28, 2010

Providing advice should be clearly differentiated from selling products. No one person/company should be allowed to pretend to do both. The so-called "two-hats" person, like the corporate "chinese walls," is confusing at best and truly absurd. Financial advisors, consultants, and planners should all be held to a high fiduciary standard. Salesmen, like brokers and insurance agents, should disclose their responsiblity to represent their employers' interests before their clients' interests.