Subject: File No. 4-606
From: Terrence O Morgan, AIF
Affiliation: AIF

August 30, 2010

I am a dually registered advisor which simply means in the 401k business I can chose to be a commissioned broker under my broker/dealer or something that is a little harder to do and puts me in the line of fire from Investment Advisor (IA) operating under the 1940 Act. Guess which one is more lucrative and easier to do with less stress? It's of course the commissioned broker. I have no responsibility to my 401k client. I can sell them the highest paid, poorest performing investment choices with no basic fundamental responsiblity to the employer or employees.

Under the Investment Advisors Act though functioning as a signed fiduciary, the world is suddenly more transparent. My interests are totally aligned with the employer and the 401k partiicpants.

We sell quite a few 401k plans. I am not a wealth planner or individual life insurance agent. I chose a few years ago to purse the 401k plan business primarily because I saw a lot of abuse in the 401k business by captive insurance agents selling proprietary 401k products with high fee investment choices and poor performing investments. Most employers have no idea what they were buying from their golfing buddy who sold them group health or a key man life insurance policy to protect the business. The purchaser of 401k plans from the CFO, HR Director and or owner of companies in America have no idea the game that is going on, what their responsiblities are to compare and review plans nor their duty to their employees. Commissioned life or health insurance agents along with stockbrokers are great sales people and perform an important service function in selling much needed financial or investment products to business America. Unfortunately, though it's a double edged sword. The same commissioned incentive does not work for the retirement plan market. Its wrong for commissioned insurance agents that bring great value and service when it comes to life or health insurance and who have no responsibility other then the word "suitability" to be selling retirement plans in America. It's wrong and not suitable.

Terry Morgan

(Attached File #1: 4606-2700.pdf)