Subject: File No. 4-606
From: Herb Harrison, CLU

August 27, 2010

I find implementing a fiduciary standard to broker dealers unnecessary. Suitability standards are taught and drilled to financial profesionals. Good financial planners, which are most planners are, have and hold their clients interest needs and desires to a very high standard. An advisor does not get repeat business by not doing so.

The regulatory requirements which are continually being added prevent advisors from spending time focusing on clients and add costs the client must bear.

Advisors and agents are being regulated out of business. Not only does a planner have to keep up with SEC regulations but state and federal regulations for insurance continuing education for life insurance, property insurance, long term care insurance, medicare supplement insurance, medicare advantage plans and now the Patient Protection and Affordability Act.