Subject: File No. 4-606
From: Sean McCann
Affiliation: CFP, New York Life

August 2, 2010

-The level of responsibility attached to an investment adviser (RIA,IAR) is much greater than that of a Registered Representative. Having worked at both, It would be unconcionable to hold a RR to a fiduciary standard. Their compensation is solely tied to sales and service, and they hold no ability shepherd accounts or provide. More than ancilliary support and information. The IAR/RIA is more educated and regulated, and files significantly more regulatory paperwork designed to mandate future high standards, disclosure and competence. You need to keep the two styles separate. Both are important. If you raise the bar that high for a RR, you will deplete the field, and utimately hurt the consumer who can't afford to pay an IAR/RIA.