Subject: File No. 4-606
From: Ryan Smith, ChFC, CASL
Affiliation: National Association of Insurance and Financial Advisors, Argus Financial Consultants

August 6, 2010

I am a financial planning professional that works with middle and upper income clients. Applying a fiduciary standard in all cases will allow some of these clients to fall through the cracks. It will not be cost effective to accept the added liability with these accounts. In fact, the added cost of fee only models will essentially be passed on to the client in these situations. So instead of being offered better advice, there will probably be less options available to these clients and the options that are available will be more expensive which will negatively effect their financial plan.

As a Series 7 and Series 66 registered individual, along with my ChFC and CASL designations, as well as an insurance license, I am responsible for a rigorous compliance and continuing education program. I estimate I spend about 15% of my time through online courses, scheduled location courses and continuing education seminars. This is in addition to the time spent everyday making sure every last application, conversation and email is compliant with my broker-dealer.

As financial professionals, we already spend days per year making sure we are compliant and educated to the highest level in order to serve our clients best. We want to see our clients succeed no matter how big or small the accounts. Changing the fiduciary model will only hurt our businesses and the clients who either lose us as advisors or are forced to pay higher fees in order to be serviced at the level they deserve.