Subject: File No. 4-606
From: D Phillips
Affiliation: NAIFA Local President

August 2, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard.
Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.

I do not feel moving to a fee-only model will result in better, unbiased advice.
Will we be forced to a fee only model to protect ourself from liability?
Most of our client's cannot afford to pay up front fees or even be willing to.
Will the liabilities drive up our errors and omissions coverage?
I personally will be unwilling to stay in the business if liabilities become too great.We are already under a microscope in this Industry, why make it any more difficult on the Industry and our clients?