Subject: File No. 4-606
From: Philip Reiter
Affiliation: Northwestern Mutual Financial Network

August 6, 2010

I urge you to reconsider forcing fiduciary responsibility on every advisor regardless of the client's situation. Doing so will force us to treat every client as an advisory (fee based) client to protect ourselves from liability. For many clients a fee based account is not in their best interest. They do not want or need that structure and it would be too costly for them compared to A share transactions that require suitability only at the time of purchase. If you force this upon us, the smaller investor will get left behind because advisors cannot afford to spend time with those clients because the revenue does not cover the overhead and time spent. I strongly urge you to rethink this idea as it will do more harm than good, especially to clients with smaller accounts who need help as well.