Subject: File No. 4-606
From: Robert G Dibley
Affiliation: Chartered Life Underwriter, Chartered Financial Consultant, Financial Adviser

July 30, 2010

Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients and simply adding another layer of regulation means another layer of compliance and yet more cost to clients.

I have life and health licenses as well as securities licenses - they all require continuing education and my CLU designation requires an additional 30 hours of PACE education every two years. My professional dsignations as well as my membership of NAIFA all have cods of ethics which I believe in.

Wer have annual compliance meetings (4 hours) as well as a required ethics and compliance exam ANNUALLY. Additionally, my office and files are physically examined every year by our Compliance division at Home Office as well as by my Managing partner.

My staff and I already spend hours every month on compliance issues and we have a full-time compliance officer with the mamanging partner.

The more layers of compliance there are the less time I have to service my clients.

I don't believe a fee-only model is any better than existing models - in fact many of my brokerage account clients will end up paying MORE if I move them to fee-based programs.

More regulation for the sake of it and more compliance oversight will just force many financial representatives to leave the business - myself included. Who then will take care of my clients?

I don't believe these proposed requirements are necessary - it is a knee jerk reaction to a few bad apples. Don't punish us all needlessly.

Robert Dibley