Subject: File No. 4-606
From: Jeremy J Ripperger
Affiliation: Director of Client Relations, Northwestern Mutual Financial Network-Fargo

July 30, 2010

To whom it may concern:

As a financial representative, I work every day of my career based on a single question: "what is in the best interest of the client?". In fact, I manage a business unit that is designed to "keep the promise" to our clients who no longer have an active representative in the business.

I understand the desire to make sure that people are being treated appropriately, and that everything that is done is in the clients' best interests. I also understand that there are those individuals that do not do what is in their clients' best interests. Having said that, I wonder, though, are we to punish the many because of the few. Is it anyone's best interest to impose new regulations that can and certainly will have extremely destructive consequesnces? In the end, are the clients any better off?

Who will decide what is in the client's best interest? What time frame will they look at? What information will they use? Will someone be there to hear every conversation? Will every single document be looked at? What if the definition of "best interest" changes?

I think that it is entirely impossible for someone else to determine a clear cut definition of what is in the client's best interest without being a party to every conversation and situation. People change. Situations change. Client's change their minds.

We have see what happened to the medical community by having attorneys and bureaucrats determine what was "in the best interest" of the clients. Has the medical profession gotten better? Are people better off. I would argue that expenses are significanlty higher due to doctors practicing defensive medicine in order to protect themselves from lawsuits. Hospitals have to charge more to compensate the doctors because of outrageous malpractice insurance premiums. Attorneys are lining their pockets with settlement money from frivilous lawsuits that the doctors and hospitals realize would cost much more if litigated even when they did nothing wrong.

We cannot be this ignorant. We cannot allow another extremely important industry to fall the way of medicine. We cannot regulate our way to financial ruin.

I implore all those involved to take a step back, remember that all actions have unintended consequences. The clients will pay dearly in the long run for this. We will look back at the decision and wish we had considered what would happen. We will wish to take it back, but by then, it will be too late.

Make the right decision. Vote against allowing this to happen to us.


Jeremy Ripperger