Subject: File No. 4-606
From: Robert M Nelson
Affiliation: Register rep, Ameritas Investment Corp (AIC) broker-dealer

August 16, 2010

Suitability standards seem to be a "slippery slope" at best. In 36+ years in the industry, I have observed many attempts to define a suitaility standard with no success. Is it the lowest cost? That seldom is the case as it ignores "value." I strongly recommend you consider a disclosure checklist for the buyer and advisor to sign. "Lowest cost" would have a Hyundai better than a do you include "value" rather than just price? That should be your focus. I have supervised the NAIFA (National Association of Insurance and Financial Advisors) Errors Omissions program for over 20 years. We cover some 5,000 agents nationally, most of whom are securities licensed. I can assure you future claims will increase with "ill-defined" suitability standards. The net affect would be increased consumer costs. We have strict supervision currently by our broker-dealers compliance departments. That system isn't broken. If new rules are put in place, they need to be clear, flexible on how "value" is defined and meaningful to the average consumer seeking to make an "informed decision." Thank you for listening. (Bob is also a Past National President of NAIFA)