Subject: File No. 4-606
From: Adam S Keller
Affiliation: Financial Representative

August 4, 2010

I have been a financial advisor for 8 years, and I do recognize the importance of this argument and the need for a sound decision and implementation of rule thereafter.

Helping my clients with their insurance and investment strategies that is both a duty and an obligation. On a macro level, I strongly believe that my position as an independent advisor is a fundamentally better way to align my interests with my clients. Had I chosen to work for a captive company I would have had to sell said company's product perhaps it's a good product but not the best for my client. I bring this point up simply to illustrate that there are a number of ways one can impose fiduciary OR suitability standards.

I believe that forcing a fiduciary standard on B/D, while sounding appropriate and good, is really just going to add more red tape, less flexibility, and ultimately more costs to the client, without strengthening an already robust client centered responsibility standard, i.e. suitability.

Thank you for your time and I appreciate you reading this.