Subject: File No. 4-606
From: Stanton Gershon, CLU, ChFC
Affiliation: Senior Financial Services Representative the Principal Financial Group

August 26, 2010

After 30 years in this business, I feel a need to express my concern over a misguided attempt to better protect the customer. Fiduciary standards don't really add any REAL benefit to the protection of the consumer. It is a sort of an after the fact solution. The damage to the customer has been done, now lets do something, kind of approach.
I feel we are far better regulated (to the benefit of the consumer) using the current FINRA and broker-dealer audits and compliance processes that we currently follow. Protecting the customer BEFORE harm happens is the best approach.
No amount of regulations is 100% fool proof, but adding this unnecessary layer just makes it far more cumbersome without adding any real benefit.
The amount of compliance rules and procedures that we currently follow are more than adequate protection. Although they require a lot of time and money to administer, I'm comfortable with their scope and feel good about how they have greatly improved our industry. Adding this additional layer is over the top and unnecessary.
The real problem with regulations is when one individual is unscrupulous, the knee jerk reaction is to punish all.
Enough already