Subject: File No. 4-606
From: Edward P. Sunter , Jr.
Affiliation: NAIFA and SFSP

August 30, 2010

I am offering my comments on the regulation of broker-dealers,which I feel are already rather comprehensive and almost to the point of making the cost of doing business more and more difficult.I would say it compares well to the standards for investment advisors as well.
I feel that in many areas of business you need good regulation to protect the public and the consumer,but you can go to far and cause reps. to look for work in other fields.That would actually allow for less advisors to provide information and education to the public.A registered rep. in my firm already has to attend a number of compliance meetings per year to mantain his license and take eaxoms and surveys on line too.We also have a cost associated with all these meetings ,surveys and exams to maintain our broker dealer rep. status and have seen ,where reps. decide to leave the business.
I think the SEC may be creating another problem for the public,if they push the liablities of a fiduciary on us.The result could be for us to increase our fees and charge fees for service.
Thank you for your consideration in reviewing these financial regulations for my industry.
Edward Sunter Jr.