Subject: File No. 4-606
From: Gregory V Cismoski

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.
I hold numerous insurance and securities licenses. All license require continueing education. In addition, I'm required to pass period exams as well.
I already devote a tremenous amount of my day to compliance and regulator paperwork to comply with today's regulations. which is already taking up my time to serve my clients.

The additional cost this will require of my practice will force me to increase my costs significantly to my clients. If they are not willing to pay the cost. I may be force to change careers and the client will suffer.
All costs will go up, the client will not be in a better position, however, they will be required to pay more in fees.