Subject: File No. 4-606
From: Paul Roa, CLU, ChFC

August 24, 2010

The suitability standard governing broker-dealers and registered representatives is already and enforced standard.
Adding another layer of regulation means another layer of compliance, and even more cost to clients and each of us as small business owners.
o My state licenses and continuing education requirement in addition to compliance reviews are more than needed to make sure we are working in the best interest of the client.
o More time in nonproductive matters leads me to question the viability of this profession. We already have full time staff in place whose sole role is keeping up with compliance?
Changing the standard to a fiduciary duty could mean less benefit for our clients and significantly hinder my ability to serve my clients with excellence.
o The additional liabilities would no doubt drive up the cost of our errors and omissions coverage?
Thank you for your consideration,
Paul Roa