Subject: File No. 4-606
From: Joseph C LeBlanc, CLU
Affiliation: Society of Financial Service Professional National Assoc. of Ins. Financial Advisors

July 30, 2010

Current suitability standards governing broker-dealers and registered representatives are already in place to protect consumers.

Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by our clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.

The time and cost of my insurance and securities license are already high. The cost to keep my securities license alone is about $3,000 and that does not include any cost of CE and my staff for maintaining records and time spent with auditors annually and occational more thatn that.

My office staff spends time daily keeping files current, which is a cost I expect to run my business effectively and keep clients satisfied. However the 8 to 20 additonal hours every year that they spend with an auditor is an additional cost which we must pay.o Are there areas of compliance that do not add any consumer protection in your view?

Moving to a fee-only model will mean less of the my client will be able to obtain affordable advise and therefore will be on their own. They simply will not pay for investment ideas and counciling because they can not afford it.

I have been in this business for 28 years and now the liabilities are becoming so that I may have to consider doing something else.

Please consider all these factors, the current problem is in not with the small independance of the country like me but the large Madoff's and Stanford's of our country. This is were the SEC's effort should be focusing on currently.