Subject: File No. 4-606
From: Kevin Draeger

August 10, 2010

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.

Currently I hold my 6 and 63 licenses. Sitting for my CFP in November. My office spends too much time on compliance and the associated paperwork as is. This regulation will only add more unnecessary paperwork and costs.

The liabilities of a fiduciary duty would mean more costs and hurt my ability to serve clients. My firm will may no longer support the CFP designation much like State Farm Insurance. This is a disservice to clients not to have this designation.

Moving to a fee-only model will result in less people saving for retirement because so many people are unwilling to pay a fee for retirement advice.

The increase in liabilities will naturally drive up errors and omissions coverage which will ultimately be passed on to the clients.

Increased liabilities will force many people out of the business which is already hurting for new advisers. This obviously will hurt the general public.

Thus, this new regulation will decrease peoples savings for retirement and increase their dependence on the governmentsocial security etc.