Subject: File No. 4-606
From: Paul B. Crouch

July 30, 2010

I have been in the Insurance industry for thirty (30) years, and a Registered Representative for seventeen (17) years. Over the years I constantly receive more layers of regulation. Enough is enough. Adding another layer of regulation means another layer of compliance, and even more costs to customers.
I must fullfill core requirements though my Broker-Dealer and study for, and pass on-line course requirements. I probably take 8 - 10 course requirements, per year. In addition to these requirements, the paperwork that is required for tranactions is becoming burdensome.
Also, moving to a fee-only model will NOT result in a better, unbiased advice. Many of my customers can not afford to pay up-front fees, nor are they willing to do such. There are areas of compliance that do not add any consumer protection.
There is the PERCEPTION that the legal fiduciary duty governing investment advisors provides greater investor protection than the suitability standard governing Broker-Dealers. This PERCEPTION is FALSE.
Paul B. Crouch