Subject: File No. 4-606
From: Janelle J Fuhrmann
Affiliation: CFP and Managing Partner for 100+ advisors

August 24, 2010

I have always been a proponent of life long learning for myself and the representatives in our region to foster the best possible advice for clients.

I want to be sure that the Frank-Dodd bill does not cause unnecessary scrutiny on registered advisors that work in the best interest for their clients every single day.

This Act does not define what the rules are for compliance with a legal "best interest" standard - thus subjecting registered representatives to the potential of never ending lawsuits. For example, is "best" the cheapest recommended product? The "best" premium relative to the benefit of the product? The product with the "best" historic underwriting and service standards? Is it the one from the carrier with the "best" rating? The fiduciary standard in essence adds a vague legal liability standard that looks back (sometimes after many years) and is enforced after the fact by the SEC or trial lawyers who have perfect vision in hindsight.
We must understand that the 'best' is not always about comparing companies and products to the nth degree but instead listening to clients and their dreams and trying to help them find a solution or two that can help them meet their needs.
I hope that the SEC does not enforce their right to scrutinize a group of industry professionals who are doing good work for families and the communities in which they live.