Subject: File No. 4-606
From: Christen Gibbons
Affiliation: Chartered Financial Consultant and Chartered Life Underwriter

August 9, 2010

I am a financial advisor and therefor covered by the suability standard model for broker-dealers and registered representatives and the fiduciary standard model. When I'm recommending a product to fill a specific insurance or investment need I work as a representative under the suitability model which serves my clients very well because it looks forward to see if the product recommendation is appropriate before it is purchased. When I'm doing more sophisticated financial planning I am an advisor under the fiduciary standard model. This is more costly because of the required reporting and ongoing service including additional advisor liability and I can only do this type of work for people that have higher income or net worth. Regardless of the model I provide thorough needs assessment and quality product recommendations when appropriate. Many of my clients would not pay for separate financial advice but still need help with their insurance and investments. The representative model (suitability standard) is usually paid for by the purchase of a financial product. Therefor the client doesn't have to pay twice to get the financial products they want. It is the least expensive way for many clients to get expert guidance and quality products.
I am required to have ongoing continuing education for insurance 15 hours every two years, Investment training 10 hours per year plus 3 hours of Compliance training per year, and 30 hours total education training for my professional association every 2 years. This is in addition to FINRA testing and my sponsoring company ongoing testing on various financial topics every year.

If you insist on the fiduciary standard for all financial representative you will force many representative to stop working with lower and middle income clients and they will be forced to go without a professionals guidance. People these days need our help more than ever. It was not the local financial representative that caused the big financial troubles our nation is facing it is the local financial representatives, one client at a time helping them to make the best of the current situation and build for a better future
We are already very regulated and our costs and time for compliance is significant. Any more regulation will only hurt the consumer and drive many local small town financial practices and reps. out of business. The internet is not a replacement for one on one interaction. People need financial representative to motivate them to take sound financial steps to provide for their families and their futures. Don't punish them as well by trying to protect them