Subject: File No. 4-606
From: Dean Forman, M.S.,CFP,CEBS
Affiliation: CEO/President GFBB Benefits

August 24, 2010

I am concerned with the progression of the last several years toward a "fee only" model of practice. While the term fee only sounds very selfless it may actually be less client centered. A fee model "wraps" a management fee ON TOP OF OR IN ADDITION TO existing asset management fees on mutual funds. In some if not most instances this raises the fee to the client by 100 to 200 basis points (bps).

Over the past few decades there has been a proliferation of classes of shares such as A, B or C shares. The latter two were seemingly non-invasive attempts at hiding annual fees. Last week the WSJ reported (again)that the PRIMARY factor in returns are FEES. Fees will need to scrutinized even more as we are in a recession and investment cycle where costs will play a more prominent role as returns are expected to be lower. This new fiduciary legislation will push investors even further into the realm of higher fees that the big brokerage firms have been pushing for years.

Regulation stifles innovation, competition, and choice while not reaching it's intended outcome. Speaking from 30 years of experience as a registered representative and principal more laws and regulation are seldom if ever the solution to those not possessed of a moral compass. Our overcrowded jails are a testimony to that. Greater transparency and protection is best accomplished through self regulation and education.

Please leave our industry free from the tethered body of regulation into the arms of higher fees and lower returns for investors and the unsophisticated.