Subject: File No. 4-606
From: John Chiodini

August 9, 2010

Sirs, I have worked for the Northwestern Mutual Financial Network for over 25 years. I live and work in a small town in the middle of Michigan. Most of my clients live in homes with mortages under $200,000, incomes under $100,000, kids that are in college or plan to go, and are trying to save for retirement in a 401k plan.
When I work with clients who have assets in excess of $1,000,000 I refer them to a wealth management advisor who will charge them a fee to manage their assets. I don't know a wealth manager who would offer their services to my average client. Who is going to work with the "average" person?
My broker-dealer, the Northwestern Mutual, holds me to the highest ethical standard. My compliance officer reviews my every transaction for suitability. Any communication with my client that references investments is reviewed for compliance prior to being sent. My compliance officer recently visited my office to review client files to make certain that the files were compliant.
The public is not going to be better served by holding financial representatives to a fiduciary standard. Problems arise when broker-dealers are not monitoring the activity of their representatives.
I am aware that many unethical transactions occur in the marketplace. Requiring all financial representatives to have a fiduciary relationship with their clients is not the answer to this problem. The rules are in place to insure proper activity. Broker-dealers need to expect and demand ethical behavior from their representatives.