Subject: File No. 4-606
From: R Farabaugh
Affiliation: NAIFA-Greater Harrisburg

August 24, 2010

In regards to Fiduciary Standards on Reps
I have worked in the Insurance and financial Service industry for 25 years. I hold almost all licenses and feel that the regulations on our business are enough. Each annuity application taken either fixed or variable is heavily scrutinized for suitability and if there are questions, the client is called to verify. Each mutual fund sold has to go through a process to determine whether A, B, C, or managed money is the most appropriate. If another layer of compliance is put on top of everything else, this will make it both onerous on us and the client. I know there are a few bad apples that skirt the rules and regulations but there are many of us who do what is in the best interest of our clients. If we did not do this, we would not be able to keep our clients. Just think of all the tranactions done in one day and how many complaints filed, very few. As in anything, we must enforce the regs we already have before instituting new ones that with short manpower, can't enforce. When the question of best interest of the client is asked, how is anyone going to know every product with every company the only way this would work is if someone name the ONE company best for each scenario. This is impossible for an organization to do let alone each agent. If the SEC made a recommendation other than we did and the SEC's recommendation would be later found faulty, could I sue the SEC similar to them doing the same to me? This will only lead to problems and if unnecessary regulations are imposed, more and more financial professionals may not be here to service their clients.