Subject: File No. 4-606
From: Edward J Kelly, MBA,CLF

August 24, 2010

- The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard.
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.
Specific licences are held and what is involved in complying with each license.
We spend too much time spend on compliance and much paperwork is involved.
The SEC needs to know what the liabilities of a fiduciary duty could mean for our costs and our ability to serve my clients.
Will we be forced to a fee only model to protect ourself from liability?
Don't think moving to a fee-only model result in better, unbiased advice.
Can our clients afford to pay up front fees or will they be willing to?
A concern of will the liabilities drive up our errors and omissions coverage.