Subject: File No. 4-606
Affiliation: NAIFA

July 30, 2010

I am opposed to the "fiduciary" concept as proposed.

I have been in the business 50 years, have about 365 clients and about 30 million under management.

I am required to complete 30 t0 40 hours of continuing education annually.

Every transaction I complete is no monitored by our compliance office as to suitablility for the client, and also as to wheter the transaction moves the client from his or her expressed goal and allocation model.

I am audited annually to determined that my records are updated and complete.

Record keeping currently occupies 20% of my time and 25% of my assistants time. To also adopt a fiduciary responsibility appraoch would require additional time which means additional cost to my clients. Since fiduciary resposiblity is necessarily backward looking the client is no better off than under the forward looking suitability and has in fact paid more for less protection.