Subject: File No. 4-606
From: Jeremy L David
Affiliation: NAIFA, MDRT

August 30, 2010

I believe that adding further regulation to broker/dealers would not produce any extra protection for consumers and could actually prove harmful by increasing the cost to the cosumer for the following reasons:
1. Compliance costs are already high - both in terms of money and high for broker dealers. I currently hold a life and health license as well as Series 6 and 63. I am required to complete 30 hours of CE including 4 hours specifically for annuities in addition to 4 hours of regulatory element in order to hold these licenses. Approximately 1 hour per transaction is spent ensuring that the files are in compliance in addition to unscheduled file reviews by a company complaince officer. While this is necessary to ensure client's are served properly I do not feel additional layers of regulation will provide any additional benefit to my clients. In fact it may serve to increase the cost to them in order to meet additional regulation.
2. The pressure to move to a fee only model will leave many of clients who may not have the means to pay ongoing fees without the ability to receive sound financial advice. This pressure could also potentially the cost of errors and ommision coverage and raise the potential liability to do business.
3. Current suitability requirements require that I disclose both the pros and cons of any financial instrument and are sufficient to protect my client's best interests.
4. The language in the Frank-Dodd Act is vague and could potentially subject broker-dealers to endless lawsuits arising from what is "best" for the client.