Subject: File No. 4-606
From: Elisha Aharon

July 30, 2010

The suitability standard is far superior for registered representatives because:

Compliance costs are already high. Time and money spent on compliance are resources that cannot be used either for clients or reinvested to grow my business.

A fiduciary duty may well mean we all have to move to fee-only practices as a defensive measure. This would not mean any better advice is rendered, but it will cost the client more money.

The cost of our errors and omissions insurance, already burdensome, will spiral upwards if our duty is made more stringent.

Finally, there is no need to change from suitability to fiduciary... regulators have plenty of opportunity to enforce ethical and fair dealing now, just as things are.

It's obvious to me what the costs are... ask yourself what would the change really gain?


Elisha "Elie" Aharon
Pacific Advisors
San Francisco, CA