Subject: File No. 4-606
From: Ron Mallam, CLU

July 30, 2010

I strongly urge you not to impose any additional misguided fiduciary standards upon registered representatives in the securities industry. Adding another layer of regulation would very likely impose unintended costs to clients. I already hold an insurance license which requires continued education every 2 years and a securities license which requires firm elements training on a yearly basis. My office is examined yearly by our broker dealer's compliance officer. We are already documenting what was said and any understandingsof conversations with clients. A considerable amount of time and careful documentation is already involved. All of these additional compliance requirements are already having an impact on the amount of time I can spend serving my clients.

In the past, I have considered moving my practice to a fee for service practice. When I have discussed this with my clients, I receive negative negative reactions. They prefer products and service where they know exactly what their costs are. They are simply not fond of paying up front fees for service.

My errors and ommissions coverage premiums have more than tripled in just the last few years. If my liabilities become too great, I will be forced to exit the business I have spent the past 34 years in building relationships and trust of my clients.

I urge you to not impose any additional layers of regulations on us as registered representatives. Studies have been performed to show that plenty of regulations are already in place.

Ron Mallam, CLU
Kearney, Nebraska