Subject: File No. 4-606
From: Brian E Worrell
Affiliation: Insurance agent

August 25, 2010

The premise behind the effort to impose a legal fiduciary standard on broker-dealers and their registered representatives is based on the erseption that the standard would provide greater investor protection than current standards. Frankly the current level of regulation is more than sufficient. Between current FINRA regulations and my company compliance department, my clients have several layers of protection. The increased level of liability that advisors could be subject to with a new fiduciary standard would be unmanageable. The cost of my professional liability insurance would increase dramatically. The current suitability standard looks forward and attempts to prevent harm to consumers rather than looking backward an detecting breaches after the damage is done. The current standard is HEAVILY enforced. Additional standards involve additional costs which are already high and if higher would be an additional cost to clients and further impact their potential returns. Current compliance standards have required my office to hire a full time compliance officer.