Subject: File No. 4-606
From: David P Dolan, CLU

August 25, 2010

I just want to express my concern over the SEC's discretion to impose a legal fiduciary standard on broker-dealers and their registered representatives.

My #1 concern is with the amount of compliance work and expenses we already are dealing with at this time. I feel adding another layer of regulation will mean another layer of compliance and added costs that may mean more costs to the clients. With the annual audits and reviews that we currently have, I will usually spend close to one week just to provide people the info they ask for. If we have more regulation, how much more time will I be spending?

This ability of the SEC to impose fiduciary standards seems very vague and ambiguous as to what their real powers are. I am continuously striving to act in the best interest of my clients and that is how I continue to keep and add new clients. If we have another layer of regulation, that is just going to mean more time jumping through hoops rather than serving my clients.