Subject: File No. 4-606
From: Margaret R Beck
Affiliation: CLU, ChFC, CEBS

August 24, 2010

As an insurance and investment professional with 32 years experience I have always held myself to the highest standard of ethical behavior. The client's best interest is always primary. The golden rule applies in every case.

The evolution of our business has created paperwork that is onerous to say the least. I understand that abuses exist, but I believe that much of the correction is over-compensation for these wrongs.

NAIFA members believe they are already acting in the "best interest" of their clients, the Act does not define what the rules are for compliance with a legal "best interest" standard - thus subjecting registered representatives to the potential of never ending lawsuits. For example, is "best" the cheapest recommended product? The "best" premium relative to the benefit of the product? The product with the "best" historic underwriting and service standards? Is it the one from the carrier with the "best" rating? The fiduciary standard in essence adds a vague legal liability standard that looks back (sometimes after many years) and is enforced after the fact by the SEC or trial lawyers who have perfect vision in hindsight.

This vague standard is unsettling to me and while well intentioned, I believe could set the stage for frivolous lawsuits.