Subject: File No. 4-606
From: Roger Gainer, ChFC
Affiliation: President-NAIFA Marin

July 30, 2010

As an IAR I am already subject to the fiduciary standard. However, I know that the majority of consumers will not pay a fee based planner like myself to help with their financial needs. Therefore, the main source of support for them will be registered reps and agents who are held to the suitablility standard. That access would be largely eliminated by creating the fiduciary standard for all advisors. Public education about the similarities and differences would be a better option for the resources that would go into broadening the fiduciary umbrella. Consumers today are intimidated and afraid of the financial challenges they face and a rapidly growing segment of our population is facing retirement and other financial challenges grossly under prepared. 83% of people retiring this year will need to continue some work just to pay their bills. This is up from 76% just 3 years ago. This is a significant problem. We need to increase access to quality advice, advisors and products, not make it more restrictive. Don't let a few bad apples spoil the entire bushel. Bernie Madoff would not have been stopped by this type of change. Better enforcement of current regulations and better consumer education and awareness would.

Thank you,

Roger L. Gainer ChFC