Subject: File No. 4-606
From: Ronald G. Pray
Affiliation: Chartered Life Underwriter, Chartered Financial Consultant

August 17, 2010

I have been in the advisory business for over 35 years. The suitability standard works and changing to the fiduciary standard will only decimate the financial advisory profession and create another specialty for the legal profession.

The most egregious problems arising in the financial advisory profession of late have been a lack of understanding by regulators and the cleverness of those in the top echelons of finance. By and large the profession is full of well-meaning people who are already working in an over-regulated environment. The liability that will be created by virtue of fiduciary standards will prompt people like myself to retire or simply quit leaving the arena open to the jackals.