Subject: File No. 4-606
From: Barry C Johnson
Affiliation: Investment Advisor Representative

July 30, 2010

I have a Series 6, 63, 65, and Life 7 Health License in the state of Iowa. Each and every one of these licenses requires continuing education and compliance on an annual basis. The current levels of compliance are effective through my Broker-Dealer, Transamerica Financial Advisors. I have an annual office audit, as well as an annual compliance conference. The present system is cost effective and does the job, for due diligence and compliance. We do not need another layer of compliance that will only do one thing-raise the cost of production, and hinder our ability to service our clients. I currently give my clients the OPTION to work with them on a fee based relationship OR a commission based business relationship. They have the choice. I earn their business, through helping them plan their financial future, to match their concerns. My clients prefer to have a choice. Don't put them in a position that will not give them a choice.
Going to a fee-based only model will ultimately cause a lot of my clients to balk at this option, and ultimately this could lead to higher costs of production, higher fees, and clients that will be "left out in the cold", from a service standpoint. I have been in this business for almost 25 years, and I am a survivor. There are other advisers, however, that may not be able to work in a one option model. Ultimately it will be the client-i.e., your taxpayers that will be hurt in this scenario.
One other item: there a a number of captive agents with captive companies that are limited on product choice for their clients, and could in no way, shape, or form commit to a fiduciary standard that is being proposed . Don't let the actions of a few, be a detriment to the majority of us in the business that take care of our clients best interests. Barry Johnson NAIFA-Iowa Secretary-Treasurer.