Subject: File No. 4-606
From: michael s farrell, CLU,ChFC

August 24, 2010

As a regestered representative of a broker dealer and a careear agent with a large major insurer for 29.5 years I have had to deal with more and more "suitability" standards imposed by my company over recent years and am concerened that a new "fiducary" standard may be added on top of this in the future. Over my career I have NEVER had any customer complaints ,lawsuits or other compliance issues although I hear about more and more of these issues in the media ,news and especially some "trade rags" I suscribe to. Although I often resent the increasing layer of a required paperwork and documentation my employer requires for submission of new accounts and the ongoing servicing of accounts I opened for clients years ago, I accepted it under the logic that "My company is a big name/target for hungry class action lawyers and we have likely more lawyers than any other financial services compant and they have to justify their existance".Now I understand that the SEC is seeking imput before rolling out new regs.Where was the SEC(and FINRA)for all those years when Bernie Maddoff was scamming people?? Isint this some kind of backlash for a scandal that happened under the SEC- not regestered representative's watch??. The "suitability standard" imposed already for Broker Dealers is has been working and has been serving the needs of Middle Americans for years(those people all the "financial planners/advisors" don't want to waste time on 'cause they don't have 6- 7 figure accounts to "manage" SO IF ITS NOT BROKEN-WHY FIX IT???