Subject: File No. 4-606
From: Rodney C Shipe, CFP
Affiliation: National Association of Insurance and Financial Advisors

August 24, 2010

Please DO NOT impose a legal fiduciary standard on broker/dealers and registered reps. There are already sufficient regulations in place. To do so will significantly increase liability exposure, compliance costs, and time expenditure while doing little or nothing to further protect the public. The costs associated with this added layer must simply be passed on to the public. Registered Reps are already required to pass stringent profiecy exams, continuing education requirements, and periodic compliance examinations of their respective offices and practices. Adding another layer (fiduciary standards) will adversely affect the level of service to the client while forcing reps to move to a ""fee based" business model and increase the cost to the consumer.

This added Fiduciary Standard is NOT necessary. Please DO NOT impose it.