Subject: File No. 4-606
From: Martin D Coulter

August 12, 2010

I am a Financial Advisor and Registered Representative for Norhtwestern Mutual Financial Network. I hold the CLU, ChFC designaitons and am a Certified Financial Planner Certificant (CFP(R)). I hold series 6,7,8 and 65. In my capacity completing financial plans I adhere to a fiduciary standard which is required for engaging in a financial planning service. When the planning has concluded, prior to introduction of specific product recomendations, with the clients permission we present the client for their consideration insurance or investment soluitons. I inform the client that I earn a commission. Alternatively, I may open an "Advisory" relationship with a "Wrap" account, where asset fees are charged, which recognizes our comprehensive service addressing personal financial and estate planning.
I do not feel a fiduciary standard should be applied to the former, only the later. In our advisory role, a fee is charged for overall guidance. I have found clients who desire this role from us and those who may not or are too small to qualify. For many, we might provide both advisory and brokerage services. I believe adherence to the rullings and guidance of the SEC and FINRA is sufficient to serving the best interest of the public. I live fearfully already that my effort to record my client noted, understanding of the clients needs and my actions my be misconstrued, misinterpreted, or viewed unfavorably in the event of potential future client or a clients estate's disatisfaction, within a suitablity standard. The demands of self examination and cooresponding recording of notes is raises higher levels of anxiety whenever engaged in a fiduciary standard. Who will judge me? What measure will satisfy the imapartial demands of "fiduciay standard" when a commission is earned? Today in our business model, we do not charge clients a fee for a comprehenive financial plan. We trust we will earn the opportunity to provide insurance, investment brokerage or advisory services, but place no obligations on the client. Consequently, I have helped many more than would be served if a fee where charged. If all brokerage service where held to a fiducairy standard I would find it increasingly unprofitable to meet the lower middle market which I often serve. As a member of the American Society of Financial Services Professionals and Financial Planners Association, I already voluntarily comply with a standard to put the needs of the client before my own. I do not favor regulators raising higher bars of new demands on my practice.