Subject: File No. 4-606
From: Maximilian A Ruszkowski
Affiliation: NAIFA

August 11, 2010

In a time of economic downturn I believe that many people forget a lot of the veteran representatives in this industry. I also believe that a lot of those veteran representatives would not be as succsessful as they are without doing the right thing for their clients. After all, a business owner that treats customers poorly is apt not to have any customers left.

It is not in our best interests as broker-dealers to have the SEC define "the best interests" of our clients for us. Sometimes what is best for our clients may or may not be whats considered best from a different perspective. In fact, it can be difficult to determine what is best without understanding the full set of facts in context.

Having an imposed Fiduciary duty only adds to the regulation, paperwork, and liability taken on by all broker dealers in this industry. To do so would raises costs, premiums, and prices. To do so would be a disservice to many clients, and to impose such a fiduciary duty would possibly cause some representatives to leave the business. This simply is not economically viable, and different measures should be taken to insure that the industry is being properly regulated.