Subject: File No. 4-606
From: George R Allen
Affiliation: Certified Financial Planner (TM)

August 27, 2010

I am a 21 year representative serving middle America in Upstate NY. I am required, by law, now to get substantial continuing education every year for the SEC, NASD, FINRA, NYS Insurance Dept and my company. In addition the designations I hold CLU, CHFC and CFP require on going CE.

With all due respect, the retail financial advisor, whether using brokerage products like Mutual Funds, or advisory programs (like Separately managed accounts or Fee only Advisory accounts) did not cause this Financial crisis.

I have clients where I use both products and some where I only use brokerage. The due diligance that I currently have to do for either solution is far more than adeqate to protect the client. It is impossible for us to forecast market direction. Most of our clients make mistakes, by getting in and out of markets- based on emotion.

While some continuity may be needed between areas of overlapping regulation I beleive the brokerage world and advisory world have adequate oversight.

On many occasions I am meeting with say a 40 year old couple, who need life insurance and disability insurance for protection purposes and their 401k is providing ample opportunity to save. I use a needs analysis and make a reccomendation. This scenario does not need to be in a fiduciary capacity.

Or, a client calls, and says, "The Small Business Administration" is requiring life insurance for the loan I am getting on my business. This does not need to be a fiduiciary scenario. My property and casualty insurance agent does not need it for offering business and liability coverage in this scenario either.

In addition I have many situations where a younger client leaves a company and wants to roll over their 401 to a mutual fund. The risk tolerance questionnaire and new account form, which are heavily scrutinized by my company are more than adequate. If this person was forced to have a fiduciary advisor- they won't find one. My overhead has gone up substantially in last few years on my advisory practice. The smaller acount client will be left behind if forced to do this, because economically, advisors can't service smaller acounts in an advisory fashion.

The area that lacks, in my opinion is the variable annuity market, particulary, these products with 'withdrawl' guarantees or Equity Indexed type products.

For example, last winter I had a client that had a beautifully diversified Non qualified managed portfolio of stocks and funds with expenses around 1%/year, get ill-advised in my opinion to move it to one of these products with expenses of over 3.8% per year. On top of that, the client already had a significant amount of tax deferred monies in IRA's and he moved almost ALL of his taxable money to this type of annuity which when money is withdrawn, is ordinary income.

Lastly, when meeting with clients, I share with them the 2-3 different ways I may be able to help them. They get ot make the decision to work with me, as well as I with them. we spend mass amount of hours each year for compliance and regulatory issues. it is cumbersome enough to think about doing more and is potentially damaging, especially for a brand new rep just getting started in the business.

Thank you for taking the time to read my thoughts. I am open for any feedback or help I can give.


George Allen