Subject: File No. 4-606
From: Jim Lammers
Affiliation: Omaha NAIFA Board Member

August 24, 2010

As a registered rep I am heavily regulated. Every piece of business is reviewed and all exchanges that are cost free are reviewed. My office is examined each year and I communicate with my compliance officer each week. To add a new layer of regulation would be very expensive and could lead to higher costs for clients. We spend a much higher percentage of time on compliance now than we did just a few years ago.
My clients approve all transactions within their accounts. If I have to move to a fee only model, the fees for my clients will increase. I do not think that this has been studied enough. I encourage the SEC to not impose this faulty standard on us. Thank you for receiving these comments.