Subject: File No. 4-606
From: Juli Y McNeely
Affiliation: National Association of Insurance and Financial Advisors

August 20, 2010

My father started our financial services agency located in Central WI 45 years ago. I joined him 15 years ago. We continue to serve multiple generations of clients by assisting them in selecting the most suitable product for their situation. We have considered moving to a fee based planning model, however have determined that it did not fit our client base. I would venture to guess that 95% of our clients would never be a candidate for fee based planning. We have many clients that put $50 - $100/month into an investment product and we would like to continue to serve them as we have for 45 years. I believe these are the clients that need our assistance most.

As advisors and members of our professional association, we subscribe to a Code of Ethics. We are heavily regulated already both by our state insurance commission and by FINRA. We have ongoing compliance audits and strive to run our practice by the book. I have 3 support staff to assist with the ever increasing volume of paperwork and compliance. I often have my clients asking why I need so much paper to assist them with their investments. My answer is always compliance and consumer protection. I will say however that having a client sign the same form multiple times simply because they have 2 or 3 different types of accounts, does not protect them. It confuses them. My fear is that we have begun to believe that more paper equals consumer protection. I also do not believe that subjecting all advisors to a fiduciary standard will protect consumers more. It will cause a significant amount of unserved Americans simply because they dont have an asset base to support that type of planning.

Frequent and thorough audits the FINRA and broker dealers will protect consumers by removing the bad actors from our industry. We would not have been able to continue in business for 45 years if we were not serving our clients well. I am asking you to allow us to continue to use the suitability standard and continue to serve our great clients in Central WI.

Thank you, Juli McNeely, CFP, CLU, LUTCF