Subject: File No. 4-606
From: Joseph Stiles
Affiliation: NAIFA member

August 25, 2010

Dear Sirs,

Thank you for considering my comments and concerns related to the upcoming SEC decision regarding new fiduciary standards on advisors.

My concern centers on the unverified benefits of making these proposed changes. As a concerned professional for several years advising and serving clients, I assess the real issue with serving and protecting the best interests of clients to be the one-dimensional thinking that attempts to make mathematical assumptions to determine what is in the client's best interests.

More critical and diverse analysis by the advisory, regulatory and corportate parties is more on target. This analysis needs to be more balanced and based on actual results versus mathematical models.

Implementing additional regulations on an already heavily-regulated business is misplaced. And at a time like the present with significant structural changes unfolding, making sure that any new changes provide meaningful benefits for all parties is what is needed.

Thank you.