Subject: File No. 4-606
From: Brian M Duggan, CFP
Affiliation: Wealth Management Advisory/CFP(R) Northwestern Mutual

July 30, 2010

I work with clients across the country, in all walks of life and income levels.

I think the current suitability standard is sufficent insurance agents and stock/investment brokers.

The fiduciary standard should be reserved for 'advisory' client relationships. These advisors (me included) are are properly trained and given the advisory nature of the client relationship (and fee based arrangement), should be held to a higher standard.

Agents/brokers are sales people...and the suitability rule is more than sufficient.

I do think that a few products should be moved to the same oversight/governance like stocks/mutual funds I'm speaking of equity indexed annuities and equity indexed life insurance.

Both of these products are sometimes misunderstood by clients and sold as 'investments'. They are currnetly regulated as insurance.

If they were regulated like mutual funds (NASD), much of the disclusures would be better and the brokers would be help to a higher standard by NASD.

Bringing the fiduciary standard to agents/brokers is much like throwing the baby out with the bath water.

I suggest addressing equity index annuities/life and making them fall under securities rules, not just state insurance rules (since they're typically sold as 'investments').


Brian M. Duggan