Subject: File No. 4-606
From: Michael M Nicholson
Affiliation: NAIFA

August 30, 2010

In my opinion, adding a Fiduciary Standard to an already complex regulatory environment would only benefit the legal profession. Hindsight is 20/20. No one knows what will be absolutely best for the future until some point in the future.

This fiduciary standard allowing a look back will only end up costing all of us (consumers and the securities industry) more.

Currently we spend many hours in class rooms, Broker Dealer meetings, and FINRA education. In addition, our BD annually does audits of our local offices, and has undergone SEC audits the last two years. Clearly, much time is spent on playing by the rules, and what is best for the client.

I've been a registered rep since 1970. I have always done what I believe is in the best interest of the client, by doing suitability questionaires with them, and matching their goals and situation, with competitive products.

We cannot project investment performance into the future. Why should a fiduciary standard be applied that would allow someone to be judged for past performance if the product sold was suitable at the time?

Suitability standards make sense. A fiduciary standard does not.

Thanks for allowing my input.
Mike Nicholson