Subject: File No. 4-606
From: Davis Green

August 6, 2010

Converting to a fiduciary regulatory method from the SEC would add an unnecessary level of compliance that will create even more costs at the broker and Branch levels. These costs are in time transferred to the client in some shape or form. These higher "expenses" create both barriers to sale as well as barriers to entry for many clients when trying to compare products primarily based on cost to own. As it is, there are enough regulations in place to properly regulate the industry. Is there an out pour of wrongdoing made by advisors? Are we sure it is not displeasure with the current state of the stock market that is driving this reform.
Perhaps the regulatory industry should focus energy on better auditing and more innovative means of communication that can be treated as Compliant. The major changes should be in allowing and monitoring means of communication that are relative to 2010 and not 1995.