Subject: File No. 4-606
From: Richard O Zimmer, MBA
Affiliation: NAIFA, Mercer County Estate Planning Council, several Chambers of Commerce

July 30, 2010

I recently passed my Series 6 63 exams. From what I've seen, the suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. The fiduciary standard governing investment advisers is applied and enforced within NY Life. In addition, as Registered Reps try to build their practices, trying to make one inappropriate short-term sale that risks both a long-term relationship and a their license is harmful to their practices.

Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients. Any additional costs could lead many Registered Reps to a fee-only model. However, I cannot charge for my services so I may need to exit the market.

Please call me at (609) 235-7689 if I can be of any assistace.