Subject: File No. 4-606
From: Todd W Swanson, CLU, ChFC, CLTC
Affiliation: Society Of Financial Service Professionals member

July 30, 2010

Fiduciary Standards are very important for the investment business. That is why our respective broker dealers impose several examination requirements, testing of our understanding of securities law, not to mention the rigorous review of each and every investor relationship we establish.
To impose more fiduciary requirements would cripple our ability to serve our clients in a professional manner. If every professional investment advisor was faced with more paperwork, the clients would suffer from our inability to review their accounts, and make recommendations to make sure their investments were suitable for their current circumstance.
We are already the most regulated industry in the United States. We are required to take extensive exams to pass the tests that allow us to become investment advisors. Only 5-7% of people taking these exams are successful, and are serious about their profession. I don't see the value of more regulation, and in my professional opinion, I would think long and hard about continuing in the profession if more regulation was required.