Subject: File No. 4-606
From: Mark Emsick
Affiliation: NAIFA, State Farm Insurance

August 13, 2010

Suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards.

Requiring compliance with 'fiduciary standards' will drive many advisers out of the market and eliminate a valuable advisory resource to consumers, especially in middle- and lower-income markets Ironically these are the people/markets that need the most help.

Additional risk of lawsuits involving registered representatives will increase costs to consumers.

Driving every registered representative to fee-only compensation will not necessarily result in better, unbiased advice for the consumer.

Competition is the key to capitalism. Increasing regulation to the point that the free market is unable to adapt to market demands will have a detrimental impact on consumers and producers.