Subject: File No. 4-606
From: Ryan Swinton, CLU, RHU
Affiliation: Vice President, Midlands Financial Benefits

August 12, 2010

I am greatly concerned about the impact additional regulation will have on the securities industry and consumers.

Suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced.

There is no need for additional regulations as the current regulations already provide strong and appropriate consumer safeguards.

Requiring compliance with 'fiduciary standards' will drive many ethical and competent advisers out of the market and eliminate a valuable advisory resource to consumers, especially in middle-income and lower-income markets.

In addition, the risk of lawsuits involving registered representatives will increase costs to consumers.
Driving registered representatives to fee-only compensation will not necessarily result in better, unbiased advice for the consumer.