Subject: File No. 4-606
From: Von W Edman, CLU, LUTCF
Affiliation: Past President, NAIFA-Kansas

August 1, 2010

I disagree that the fiduciary standard has protected consumers better. Basically, the fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes. My business is already heavily regulated and my company provides a compliance standard to protect our clients. It is always the "prudent man" that looks out for their clients, by understanding their financial circustances, knows there wants and needs and make recommendations based on that situation. Since the investment environment can change quickly, one must always provide updates to clients and re-evaluate their circumstances as needed. Current rules and regulations provide a sufficient level of protection for all, the client, the company and the rep.