Subject: File No. 4-606
From: Paul M Johnson
Affiliation: Registered Representative

July 31, 2010

I am licensed to sell securities products and fee-for-service. Since receiving my licenses 6, 63 and 65 starting with the first two in 1989 I have loved serving my clients, who with me have disliked the burdens placed on us, both, by regulations.

While there may always be a very tiny number of infractions, the current standards for compliance will always keep the vast majority of registered reps (RR) in line with the rules.

So far, all of my clients choose, freely and with all the relevant information, to pay a load and 12-b-1 fees because they make more money, which is my goal. However, if you are going to force a defensive practice on my work I will be willing to explain the terms of the new rules and thus the need for fee-for-service work, instead.

Every year I am required to go through many hours of testing and continuing education. Like my colleagues, I do well.

I work with and enjoy the honor of serving my clients. Since 1989, the number of requirements has ballooned. Only since 9/11 have my clients been less reluctant to complete some of the forms that we must submit.

More requirements will not improve the quality of service to clients. That quality has always been there. As a member of NAIFA I know that I work with many professionals who share the highest integrity.

The tiny number of people in our business who intend to break the rules OR who refuse to pay attention to them will be there always.

More rules will not make them go away. I can think of many other sales/service people in other industries who do a wonderful job but get tainted by the tiny number of those among them who seek to ignore or scam the systems and rules.

Yet when I had fewer rules was my service lower in quality or less careful about informing and protecting my clients form adverse decisions? NO

I want them to make the most money they can that is suitable and that serves their best interests.

Every aspect of my industry is filled with people who serve well. Also, the efforts by FINRA, my broker dealer (ING Financial Partners) and its representatives have never lacked in the care to make sure that compliance with and understanding of the rules is clear and seeks to keep all of us aware.

I know that the SEC seeks to protect the American people from being cheated. Yet, all the rules and new ones - cannot absolutely guarantee the outcome in 100% of all cases.

Members of Congress, oil companies, car dealers, gun salespeople, people in the multitude of other service companies seek to do their very best. Yet, all it takes is one or a few to mislead people to think that all of them are bad.

Like all of the above I enjoy the fulfillment that comes from great representation.

The hardships created will cause some to leave the profession and reduce the competition. While I find some value in that, I think we all know that competition makes us better.

Every time there is news about a failure of ethics or professionalism people become more careful of their decisions. A new rule will not produce that.

Let's not tarnish a great profession or make extra work that becomes burdensome and interferes with high quality of service that we provide.

Thank you for your time with my thoughts. Since you get many of those thoughts, I hope that this message provides some value as you, too, seek to serve.