Subject: File No. 4-606
From: Joseph Chalom

August 24, 2010

I urge the SEC not to impose additional regulations on registered representatives. 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 currently hold a life, health and variable annuity insurance license in addition to a series 6,22,26. I spend a minimum of 15 hours a year in ongoing education.
In addition I am examined annually.
One application currently takes approximately 45-60 minutes to complete.

I believe that imposing a fiduciary standard on all advisors will dramatically reduce the number of advisors in the profession while not assuring the consumer greater protection.

Unfortuantely, there will always be people who wish to do others harm. These unscrupolous individuals should be and can be weeded out of the profession, with our existing regulations.