Subject: File No. 4-606
From: Harry A Shepler
Affiliation: Chartered Financial Consultant

August 6, 2010

There is an inherent conflict between a broker and a financial adviser. One represents his/her company, and the other represents his/her client. One is compensated by commissions from the financial institution, the other by fees directly or indirectly from the client. Fiduciary standards are inherently different. One cannot represent both parties, a company and a client, at the same time. Suitability safeguards are already in place for the broker. Fiduciary standards are already in place for advisers. Please understand that a unitary standard for both is unworkable without the destruction of company sponsored brokers on the one hand or the compromise of the fee only adviser. As in the brokering of real estate, automobiles, and most retail establishments, most Americans cannot afford to make a product purchase and pay an independent adviser at the same time. Only the wealthy can afford both. A unitary standard for brokers and fee only advisers would necessarily adversely effect most Americans' access to financial products at reasonable cost.