Subject: File No. 4-606
From: Elizabeth A Brooks
Affiliation: Allstate Financial Services Personal Financial Representative

August 26, 2010

I believe that the current suitability standard is the appropriate standard for broker dealers and registered representatives. The vast majority of us work with middle income americans that will lose the valuable resource a registered representative now provides to them if the new, vague fiduciary standard takes effect. The vast majority of registered representatives go to great lengths to act in the best interest of their clients in helping them plan for their financial future through insurance and investment products. Consumers know they have options in the marketplace and have every right and responsibility to explore that marketplace prior to making decisions. It should not be the responsibility of the registered representative to do that homework on behalf of the client. We can only adequately represent our own products certainly not every available option in the market so as to tell our clients they should be buying a different product from someone else. This fiduciary standard attempts to protect the consumer from himself as well as from the few bad actors that will always be in our midst. This is an ill-conceived way to accomplish that objective. Careful the unintended consequences this standard could bring.