Subject: File No. 4-606
From: Ralph M Sabbagh
Affiliation: National Association Of Insurance Financial Advisors

August 1, 2010

July 31, 2010

To Whom It May Concern:

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. I disagree that the fiduciary standard has protected consumers better. Basically, the fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.

Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.
I hold Series 6, 7, 24, 63, 65 registrations, and comply with all of the continuing education and reporting requirements.
I am currently subjected to quarterly inspections and examinations by my broker/dealer.

There is more than enough existing regulation. My I suggest for your consideration that you simply enforce existing regulations. There is no need for more oversight


Ralph M. Sabbagh