Subject: File No. 4-606
From: Dennis Wong, CLU, ChFC
Affiliation: Member of: Society of Financial Service Professionals and National Association of Insurance Advisors

August 24, 2010

As a licensed Insurance Agent and Registered Representative, I must adhere to client suitability standards as required by my license (required per compliance of the insurance companies that I represent), professional associations (voluntarily per industry support) as well as my broker/dealer's registered representative compliance requirement. As a professional I also consider my relationship with my clients as a "fiduciary" per my business ethics. Having regulated "fiduciary standards" for registered representatives (differentiating from Stock Brokers and Investment Advisors) does not make sense since fiduciary standards are a subset of "suitability requirements" i.e. one who maintains suitability analyzes is performing one's fiduciary's duties

As a registered representative, I do not recommend investments but assist clients in the execution of their financial plans, which includes but not limited to the acquisition of financial products.