Subject: File No. 4-606
From: Bradley Schlafer
Affiliation: NAIFA National Association of Financial and Investment Advisors

August 9, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Currently, I spend at least 15-20 hours each month keeping up with compliance regulations, filling out the proper blotters, filing reports and so on. One more regulation is not needed and the ultimate expense of all these regulations gets passed on to the consumer. I have been in the industry for almost 20 years and can honestly say the rules and regulations today are tighter now then ever. Yes, some firms/registered representatives do not follow the rules, but forcing everyone to a Fiduciary standard is not going to drive those people out of business. We need better enforcement of the rules and regulations we already have on the books---not more rules.

If I was to move to a completely fee only business, many of my clients would have to find someone else to help them plan for their retirement and other financial dreams. I would be forced to charge them a fee that they could not afford. Who is going to help the lower middle class people? The big, big firms already ignore them and Fiduciary regulation will force another group of Registered Representatives to ignore them as well.

I am concerned that the subjectivity of what is best will significantly raise my liabilities. That unknown risk will substantially raise my errors and omissions coverage and make it more difficult to stay in business. I believe many people will leave the business, which will mean people will not have someone to help them plan for the future.

Please do not submit our industry to a Fiduciary standard that will create a very difficult environment in which to work and help people.