Subject: File No. 4-606
From: John W Gruber
Affiliation: Living With Money LLC

July 29, 2010

I believe we in the advisor community owe our clients a fiduciary standard of care in providing advice and service. I am concerned, however, about the potential impact of setting fiduciary standards that make offering and delivering our services to lower income and lower net worth clients unprofitable, which is likely to result in a considerable withdrawal of advisors from that segment of the market.

Standards of care should be established for services rendered to all clients, but there should be consideration for the practical limitations of providing advice and service to certain segments of the client population.