Subject: File No. 4-606
From: Jeffrey D Van Strien, CLU ChFC

August 6, 2010

A fiduciary standard is not necessary for registered reps. FINRA and RIAs do a vey good job of self regulation.

Consumers would be harmed because of potentially increased fees. Many consumers would elect not to pay a fee for advice.

Under suitability standard and commissions reps are paid when customer takes action that is in their best interest. If not, rep either doesn't earn future business nor earn referrals to others. Further RIA compliance monitors suitability.

There is no need to change to a fiduciary standard.