Subject: File No. 4-606
From: Faye M Osborn
Affiliation: NAIFA NE President

August 19, 2010

I have been involved in the insurance and financial service profession for over 28 years as Agent, Registered Representative, Securities Principal and Advisory Associate. I feel very strongly about the Fiduciary Standard being considered and how it could undermine the Broker/Dealer business model and rob investors of an inexpensive financial guidance and give a premise that everyone fits under the same mold. The freedom to choose how to pay for financial products, services and or investment advice needs to be available for all, or the cost of doing Financial Services business for the middle to lower income markets will surely increase.
Requiring Fiduciary Standers on us will drive many Advisors out of the profession due to additional risk of litigation, cost and time with an added layer of regulations. I believe that under the Suitability Standard the public is well severed. The Broker/Dealers and their Registered Representatives are meeting the client needs and timelines while enduring a very stringent regulatory environment that is stronger and more demanding then the Fiduciary Standard.
I am asking you NOT to implement a Fiduciary Standard (Single Standard of Care) on our profession it will create an economic hardship on our industry and clients.