Subject: File No. 4-606
From: Charles G Nahatis, CLU, ChFC
Affiliation: Registered Representative

August 17, 2010

This is a request to Stop the SEC from imposing a fiduciary standard to registered representatives.
As a registered representative, I am regulated by FINRA and by my broker dealer. My broker dealer makes 2 announced and one unannounced visit to my office per year, they require me to submit all investment sales to them for suitability review prior to accepting new business. I maintain several logs and detailed client notes. I have continuing education requirements to meet annually and I generally well exceed those requirements. My E O insurance is well over $3,000 per year and in my opinion the proposed "fiduciary standard" would make work more cumbersome and result in a substantial increase to my E O premiums based upon the additional liability the fiduciary standards would impose. Furthermore, these standards, in my opinion would not provide any meaningful additional consumer benefit.
I work for my clients and I strive to do the best of my ability to benefit them. The additional regulations would only add an additional level of paperwork and redundancy to my practice. I urge the rejection of adding a "fiduciary standard" to registered representatives.