Subject: File No. 4-606
From: Kristy J Cavanaugh
Affiliation: NAIFA

July 30, 2010

I believe that the suitability factor weighs much more heavy on protecting the consumer than the fiduciary factor.

Basically, the fiduciary standard looks back. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.

The suitability standard governing broker-dealers and registered representatives is already a very heavily enforced standard.

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.

Thank you for re-evaluating your thoughts on this topic of fee-based models.