Subject: File No. 4-606
From: Cliff F. Wilson, CLU, ChFC, CLF, LUTCF
Affiliation: NAIFA

August 26, 2010

I appreciate the opportunity to share my thoughts on this issue of critical importance to the American Public. I do not agree that the Fiduciary Standard has done a better job protecting consumers. The Suitability Standard is well enforced and Registered Reps have numerous education and compliance requirements. Does a Fiduciary Standard have the potential to increase costs and add additional regulatory and compliance requirements... Yes. But the real issue is the public having access to ethical representatives, properly regulated, who may choose to operate through various business models. I believe this is, and can continue to be done through a Suitability Standard.
Thank you.