Subject: File No. 4-606
From: Dennis M Dean
Affiliation: NAIFA

August 25, 2010

Please reconsider any new fiduciary requirements for registered representatives. As registered reps, we are already subject to audit by our broker-dealers, the companies we represent and state and federal regulators.

If the future business model only allows for fee-based reps, a large sector of the middle market will not have affordable access to the financial services that we offer.

This anticipated action will reduce, not increase choices for consumers, and will ultimately inhibit the purchase of products and services that allow families and businesses to be self reliant.