Subject: File No. 4-606
From: Roger R. Ruden
Affiliation: National Association of Insurance and Financial Advisors

August 2, 2010

Please do not make registered reps be held to the fiduciary standard-we are regulated enough. In the 18+ years I have been in this business, the amount of paperwork has approximately tripled and I've had to hire an extra person just to fill out all the extra compliance paperwork and maintain all my compliance files. Being held to this standard would add additional costs to the financial planning process which would be passed on to the client who has already tightened their belt due to the recent economic downturn. The very people this is meant to protect wouldn't have to worry about it because they wouldn't be able to afford the services offered since the prices would have to increase substantially. It would also make for a very litigious environment because it's very hard to define "best". I would have to provide my client the very "best" solution to their problem without the luxury of knowing what the future holds and then if the economic environment changes, I could be sued for something that I have no control over. The cost of errors and omissions insurance would skyrocket and probably force many advisors out of business. It would be an unending nightmare. The current system of suitability standards has worked pretty well on this level. The corporate level is where the effort really needs to be concentrated because we obviously have a lot of problems there and I don't believe imposing a fiduciary standard on reps is going to improve the big picture. The current system weeds out the "bad apples" and lets us help the most clients who need it. Please let me know if there is any way I can be of help.