Subject: File No. 4-606
From: Robert Thurmond
Affiliation: Registered Representative, NYLIFE Securities LLC

August 27, 2010

- The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. The vaguely worded fiduciary standard will not provide additional protection to my clients. Further, the proposed fiduciary standard would expose me to significant additional risk and costs.
- Such additional costs would include compliance costs (the financial costs of and time costs would be high).
- I am examined by an internal compliance specialist annualy. The examinations are random and unannounced. The standards of the examination are put together from SEC/FINRA/WA State requirements as well as standards that are developed by my broker-dealer.
- Compliance already costs me 40 hours per year in prioductive time. The time is spend in paperwork handling, mandatory training, and inspections.