Subject: File No. 4-606
From: Georgia G Bruggeman, CFP

August 11, 2010

I am a fee-only comprehensive financial advisor. I receive no compensation from any product I recommend. I am in support of immediate annuities as a part of a retirement plan but do not sell these products. I do recommend life insurance, disability but again I do not receive compensation from these recomenations. I made the decision to structure my business this way to insure that there were no conflicts of interest and to show my clients that I had no ulterior motive for recommending one service or product over another. The recommendations are what is best for their specific situation.
How can a client ever know why an advisor recommends a product when the advisors compensation depends on the sale of that product? The scope of the relationship between a broker and their client versus an advisor and their client is also completely different as evidenced by the following quote from "Schapiro: SEC is soliciting input on fiduciary issue" Investment News, Mark Schoeff, Jr. August 8, 2010:
"The bill stipulates that charging a commission and offering proprietary products are not necessarily violations of the fiduciary standard. It also says that broker-dealers won't have a continuing responsibility to their clients after the sale of a product. "
Fiduciary duty means putting your clients interests first and disclosing all conflicts of interest. How does selling a product to someone and then having no continuing responsiblity to that client constitute fiduciary duty?
Unless the entire compensation structure for the commission based brokers is changed i see no way to truly protect the consumer from predatory salespeople. The only way to protect the public is to educate them on the differences between fee-only, fee-based, fee-offset and commission based brokers/advisors. Explain the differences between being registered with the SEC and being a registerd representative and teach the public how to do background checks on brokers/advisors. We do not necessarily need more regulation we need existing regulations to be enforced and brought up to date with changing financial markets.