Subject: File No. 4-606
From: Richard A. Gurdjian , CLU, ChFC

August 24, 2010

I am a licensed life and health insurance agent. I hold a variable contracts license as well as a Series 6, 22 and 63.

FINRA has a continuing education requirement that I comply with. I have a Broker-Dealer Firm Element requirement. I have a requirement for continuing education for life insurance, long term care insurance and for annuities. Some of these requirements vary from state to state.

Costs to comply, both in terms of finances and time,are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients. And, there is no evidence that the client will be better served.

The suitability standard governing broker-dealers and registered representatives is already a robust and heavily enforced standard. The liability of a fiduciary duty would mean additional cost. This, I believe will cause many registered representatives to give up their registration. If that happens, many, many well served middle class Americans will no longer receive the help they want and need.

I would urge the SEC to NOT impose a legal fiduciary standard on broker-dealers and their registered representatives.