Subject: File No. 4-606
From: B Remo
Affiliation: Financial Advisor

September 2, 2010

In regards to the role of Investment advisors or Broker-Dealers in working with their client base, these are a few main points that should be addressed. In doing so, you will take care of most of the multitude of issue regarding this issue. Ultimatley, clients need to take responsibility for the advisor they choose and the advice they follow. Just like any service that is contracted for, ie, a plumer, auto mechanic, homebuilder,CPA, etc...People need to do some basic homework on both investments as well as who they choose to do business with. The governments role, if any, should be to make basic information resources, free from bias, or preference (i.e..don't show preference based on cost etc...)to investors in a central location (IE..Simple Web site). At this site you should also be able to get access to FINRA Broker check reports etc.

2nd Either reinstate Glas-Stegal act, or increase educational, and standards requirement for Insurance agents who sell investments, or insurance as an investment. Do serious reform on the Insurance Industry in regards to variable annuities, as most clients are misled on a daily basis about these products. Also bring compensation in line between variable annuity products that involve mutual funds. When buying funds, you can achieve breakpoints where the customer pays no commission for investing in excess of $1,000,000,(1% to advisor) but with a variable annuity if an advisor invests $1,000,000 they can make 5%+ on that investment. The difference in cost structure between the two products temps many advisors to steer clients to investments they are not suited for in order to make profit.

Last and most importantly, is give investors who work with advisors the freedom to pay for servcies as they choose. As an advisor, I live in a 1% world and even that is begin threatened. I can think of no other industry where you are asked to work for 1% or less, regardless of how much work you do for a client. Some clients prefer to pay a fee, others prefer to pay per transaction, and some prefer to pay within a fund (12-b1 fee). For a client with an IRA account that doesn't know if they'll keep a fund more than 7yrs, it's cheaper for them to buy a "c" share and pay an extra .75 to 1% annually, and have it taken from the fund therefor paying for the services provided out of the IRA without having to take a taxable distribution. If you keep trying to restrict the way advisors get paid for the services they provide, you just end up hurting the consumer.

The best thing the govt can do is to let the free markets work, make education essential for both advisors and the public, and let people make better choices. You can never avoid people trying to take advantage of investors, but you can make the punishment fit the crime, and keep people that should be advising from doing so... I hate to think of the work I do, that I never get paid for, or even acknowledged, and what makes me even more disguisted is a govt that can sit back, and cast judgement on me, and make rules for me, not knowing a damn thing about what I do. Simply put, just let people work, let them charge whatever the market will bear, and do you job on the licensing and educational end.