Subject: File No. 4-606
From: Peter Morris

December 16, 2010

I am a financial adviser that always puts his client's interests first, so I do not have any issue with holding all advisers to a fiduciary obligation standard.

On the other hand, I do not think a fiduciary standard should be confused with fee-only compensation models, as the article that provided the link to the SEC public comment website seemed to be doing. While true fee-only advice is often held out as the ideal, it is also the case that many middle Americans will not write a check up front for advice and a financial plan. As a result, if the whole world were fee-only, fewer people would get quality financial help that they desperately need. Another set of people will pay for a plan, but then not implement any of it, so they do not ultimately benefit from improved financial position. (And the financial planner does not have any incentive to make sure that the plan is implemented.)

Quality, successful financial professionals can maintain true fiduciary standards of care putting their clients' interests first, even if their own compensation comes as a mixture of flat fees, assets under management percentages and sales commission proceeds on products that will benefit the client's overall financial world.