Subject: File No. 4-606
From: Lawrence E Lounds, CLU, ChFC
Affiliation: President, Security First Benefits Corporation

August 24, 2010

I am a registered representative and work with individuals at all income levels. The main focus of my business is employee benefits but am often asked to provide assistance with personal financial planning. As a registered representative I am governed by suitability standards. These standards are strictly enforced. We have annual audits by our broker-dealer and stringent compliance processes. The costs to comply are expensive and time consuming. A fiduciary standard, as another layer of compliance, would serve no purpose except to increase the costs of compliance which would, in many instances, make the services unaffordable to many individuals. The fiduciary standard would not add any additional consumer protections.

A fiduciary standard for registered representatives is a bad idea and should not become a standard for registered representatives.