Subject: File No. 4-606
From: Kevin D Frost

August 2, 2010

While the idea of forcing all investment advisors to maintain a "fiduciary" responsibility sounds great on paper, it is very difficult to implement in reality.

My clientel consists of many small investors. Many of whom have small accounts with a few thousand dollars in each. It would not be practical... in fact... it would be impossible for me to take the time to visit annually with each of them in order to maintain my fiduciary responsibility. My income off of each one of these individuals is minimal, only a few dollars each year. Financially, it is not possible for me to devote that amount of time and physically, I do not have enough time to visit with them annually.

I am very careful to make sure their investment accounts are well diversified at inception and anytime changes are made to the account going forward. We make an attempt to meet with most of them over the course of the year but is impossible to make that promise to everyone.

I recognize the SEC's desire to protect investors. By implementing this rule, you will effectively eliminate financial advisors from working in the small and medium sized markets. Because the compensation is so small, myself and many others will simply decline to work with those individuals leaving the majority of Americans with no quality financial advice the opposite of the intent of this rule.