Subject: File No. 4-606
From: Thomas C Guebert

August 3, 2010

Another layer of regulation is not needed. We already are served and governed by heavily enforced standards. I currently hold the state insurance license for insurance products (life, health, property and casualty), the CFP license which has a very stict adherence and review Board, and my securities license for which I am reviewed annually by my Home Office and every three years by the State of Il. I keep detailed client files and am audited annually again by my company.

This additional regulation will only add another layer of compliance and more cost of operation, which will ultimately be passed on to the clients. A fiduciary model will force many advisors to move to a fee based service only and then will the client be able to afford these up front fees? And, would these new rules and fiduciary liabilities cause a higher errors and omission rates or even be available?

Please consider allowing the current program to govern.