Subject: File No. 4-606
From: Derrick P Morton
Affiliation: CLU, ChFC

July 30, 2010

The already burdenson compliance issues we have as a S6, S7, S65, and S24 Rep are emourmous. These compliance iisues cost us in time, record keeping and so many "Disclosure" forms and sinature that the client ends up more daxed and confused. Additionally it is the people that deliberately breeak the rules that cause these problems and more rules will only burden down the honest rep while not stopping the intentianal cheats. These additional rules also burden the regulatory agencies allow the intentional cheats to go undetected longer. I have daily, weekly, monthly quarterly, and annual compliance duties and reporting that more layers will not help. They will only drag down our ability to help our clients while adding additional fees and costs. as a result we spend 1 to 8 hours daily on compliance. i have two individuals in a very small office plus myself consumed in making sure we comply with all the rules. The many layers of compliance does little to protect the consumer as the volume of information required limits meangful communication and client understanding of what they have. There is less time on what things are and how they operate and more time on meaningless rules and regulations that do nothing to help the client understand the risks and rewards they have.

Fee only seems to have a perception on nonbiase recommendations, yet if you look at fee based planning the same over all bias still works. In my opinion a fee planner has less responsibility for suitability and achieving the clients goals because they get paid regardless if the client is happy in the investments. They will make recommendations to generate fees which are more expensive than commissions which must be earned each and avery time with a satisfied person seeing the value of the offering. Fiduciary responsiblility subject to so much interpretation there is no way any one could comply causing additional regulatory risk that can not be standardized or predicted. Again the cheats that will break the rules any way don not care. Honest ethical reps are already practicing in the best interest of their clients or they will not have any clients left.The advice I have seen from fee based planniers is lame and frought with bias on funds. Additionally most plans are never implemented as the planner is paid regardless therefore causing more harm and no action. As a result this rule will unduly force us all to be fee based and less involved with our clients actually putting the plans into play. MORE REGULATION IIS NOT THE ANSWER you do run the risk of pushing out the small to medium investor forever, as planners fees will always go up eating up the monies these people could have otherwise invested.

Thank you for your time . Do not add to these costs and burdens just enforce what we have.