Subject: File No. 4-606
From: James R Denny, III
Affiliation: Registered Rep

July 30, 2010

I have been in the financial services business for over 30 years. The amount of regulation in place today subjects consumers to too much attention to issues not related to their core problems and concerns. In fact, most think many of the questions we ask and the amount of paperwork they have to complete is laughable. Today we seem concerned more with money laundering and the sale of life policies to life settlement companies than we do helping consumers build and protect savings and wealth. The suitability systems now in place do a good job of educating consumers about how different insurance and investment products will help them achieve their goals. I think consumers are far better educated today and understand how these contracts work and how much they cost. My concern for the fiduciary standard is that too much attention will be placed on the plan and the advice and not enough on the implementation. I think our current system does a good job in helping with the implemtation of plans. For many of my clients and prospects it is this step which will provide them the greatest level of future security.