Subject: File No. 4-606
From: Richard G Cunningham, Jr.
Affiliation: Member NAIFA

August 27, 2010

I oppose further regulation because of teh following

Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.
o I hold a registered representive licence and have to take regular compliance modules at testing centers focusing on suitabilityo
o I have had to hire someone in my office so that i adhere to compliance regulation and spend no less than $15,000 per year on regulatory paperwork and files already.
o We are under such scrutiny through internet communication, file review already, that any more would be a hindrance
o We continue to adhere to new compliance regulationos, like projection or ledger illustrations, that any more woudl be superflous and damaging to my ability to grow my business and help my existing clients
o If we have to move to a fee-only service, people will get less service and overkill, and i believe it will lead to more "churning" because of the fee driven advisor's need to get more face-time.
o Added liabilities will drive up my errors and ommissions insurance and drive an even more litigious environment when the opposite is needed. Doctors have finally received relief from this in Texas and the profession is starting to thrive here more than other states.