Subject: File No. 4-606
From: Gretchen M Rehm
Affiliation: NAIFA

August 24, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and 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.
We hold series 6 and 63 licenses which require extensive amounts of training and continuing education.

We spend hours keeping track of transactions,following suitability standards, and even more time changing forms because of new laws that come out.

There are many issues of compliance that prohibit from helping our clients especially in the annuity market.

I work with a target market of teachers and they can not afford up front fees and most of them would not be willing to pay those.

Currently, it is very difficult to get clients to even put money away and when we start to add more fees they will stop doing this all together which is horrible for our economy.

If we have more exposed liability than our errors and ommissions with go up significantly which will cause reps to get out of the field, quit selling, and ultimately hurting consumers.

please stop this