Subject: File No. 4-606
From: Lorne T Hargis, Jr
Affiliation: National Association of Insurance and Financial Advisors

August 25, 2010

The proposed fiduciary regulations should not be implemented.
These regulations are apparently designed to penalize the investment banks and Wall Street firms from doing what they should not be doing but that would all be after the fact.
The Suitability requirements that brokeer/dealers have in place for its registered representatives already achieve what is right for the consumer. Specifically that means when a sale is proposed it is reviewed to make sure the securities proposed for purchase actually meet the needs and investment tolerance of the consumer. These requirements are proactive.

The current fiduciary regulations are sufficient for registered representatives and small busineses which implement or are considering implementing a retirement plan for the benefit of its employees. Further restrictions of the fiduciary requirements could prevent a small business owner from installing a retirement plan which would be detrimental to the long-term financial security of its employees.