Subject: File No. 4-606
From: John M Wilbanks
Affiliation: LUTCF

August 5, 2010

To put an agent that is usually a single plan agent for a client to the same fiduciary responsibility as a CFP does not make sense. The two are completely different, dealing with different levels of clients and types of plans or planning. A CFP can charge a fee and an agent can not. The forms used by a CFP are comprehensive in nature and an agent may only be providing insurance to cover the mortagage. If a client purchases a product on the internet, is the internet company required to have the same fiduciary responsibility? I think not. Do not try to over kill our industry by over complicating it, the middle market will be under served, the agents that help these people could leave the industry and there could be a void for a majority of Americans.