Subject: File No. 4-606
From: Thomas F. Flournoy, III
Affiliation: Insurance Agent and Registered Rep

August 26, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. We spend many hours a week just keeping up with existing requirements, forms that must be submitted every Friday, and applications that have excessive disclosures.

Each year we are subjected to a thorough inspection of our files and our practices by a member of the compliance team. After over 44 years of working with clients and having no one lodge a complaint for any reason, I am still required to complete ethics exams and attend an annual regulation seminar.

The fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes, which work.

For my entire career, I have always put the clients best interest foremost in every discussion and recommendation. Additional regulations will not alter that practice, and will only increase the regulations we must follow which just means more paper work and time away from the clients.

We are already regulated enough. Please do not go forward with this fiduciary standard governing investment advisers as it is not necessary.