Subject: File No. 4-606
From: John O Todd, III
Affiliation: NAIFA member

August 24, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced.
Compliance costs-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.
o I hold Life/Health licenses, series 6 and 63. I have annual compliance reviews, complete continied education requirements as mandated.
- My office has a full time compliance officer
- if forced to charge fees only, many of my clients will go unserved.