Subject: File No. 4-606
From: Fred Manas

August 9, 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.

Will moving to a fee-only model result in better, unbiased advice? NO.
Will you be forced to a fee only model to protect yourself from liability? YES.
Can your clients afford to pay up front fees or will they be willing to? CANNOT AFFORD UP FRONT FEES NOR WILLING TO DO SO.
Will the liabilities drive up your errors and omissions coverage? DEFINITELY
Will you stay in the business if liabilities become too great? NO