Subject: File No. 4-606
From: Michael A Lugo, RHU
Affiliation: NAIFA, NAHU, AHIA

July 31, 2010

To whom it may concern,
I respectfully oppose further regulations regarding Fiduciary Standard on Registered Representatives. It is my contention that further compliance costs-both in terms of finances and time-are, the current regulations the I as a Registered Representative are already very high. These costs are eventually felt by my clients. Adding another layer of regulation means another layer of compliance, and even more cost to me and my clients.
I currently hold both insurance and securities licenses and spend at least 20 30 hours a year to fulfill the continuing education and compliance requirements.
I run a small insurance and securities based practice and am examined by my Broker Dealer at least one time per year.
The current amount of paperwork and documentation that I deal with has doubled or tripled the amount of time it used to take me process a transaction compared to per say 5 years ago. This has caused me to hire an additional 20 hour per week employee to help with the extra regulatory requirements, which in turn has caused my profitability to decrease. Thank you for you for taking the time in considering my views.