Subject: File No. 4-606
From: Lisa M Mancinelli
Affiliation: CLU CPCU

July 30, 2010

I am writing to object to adding another layer of regulation to registered representatives. As a registered representative, I already act in the best interest of my clients.

The suitibility standard governing my activities with clients is already robust and heavily enforced. Compliance costs, both in terms of finances and time, are high and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance and even more cost to clients.

The fiduciary standard adds a vague legal liability. I recommend the SEC not to impose a misguided fiduciary standard on registered representatives.