Subject: File No. 4-606
From: Randel Blake, ChFC
Affiliation: owner, Blake Financail Services

August 1, 2010

For more than thirty years I have been a financial services practitioner. A large portion of my work involves benefit plans and the participants who are transitioning into retirement. I am licensed as an IAR through my corporate registered investment advisor and thus can and do sometimes charge fees for my work. But many of the people I counsel are 401-K plan participants, other than the owners or managers. These solidly working class and middle class populations are just not accustomed or receptive to paying fees for financial services. If they were expected to pay fees to consult with me upon their retirement, many would not meet to discuss important topics such as age appropriate asset allocation, target date planning or their retiremnt income options. I provide a high value service to these people and am only modestly compensated by earnings generated from occassional IRA rollovers and retirement income planning. People often have anxiety about their post-retirement income security and I can't imagine that the SEC wants to create a situation that may discourage them from seeking financial help just when people need it most.

Supervision and compliance are a big part of my business life. All my securities related correspondance is checked by others, my e-mails are scrubbed and archived. My business cards, literature, web site, newesletters and even my birthday cards must meet compliance approval prior to use with clients. I am required to maintain a no-call list, a checks-received log, a complaint file and I must store inactive files for years. I am also subject to and receive unannounced, in-person compliance visits by persons authorized to shut down my office while they rifle through my office and examine each and any document for the most obscure omission or mistake. I then am required to agree to remediation actions and promise never to make a mistake again. In short, my small office is subjected to extensive and continuous compliance supervision meant to protect the interests of my clients and the public at large. There is so much checking up going on that even the compliance officers have a difficult time keeping up with it. (witness the SEC supervising Bernie Madoff). Any more compliance requirements may in fact prove counter productive.

As for the SEC's interest in the "best interest of the customer" standard, I have this to say: Although the term is vague, subjective and open to interpretation, I can assure you that in my practice it always governs. I agree with the SEC's goal to assure unbiased advice to the customer. But I am afraid that if the SEC continues its drive to establish the proposed "best interest" standards all you will end up with will be more lawsuits and no more protection for the public. Don't let the pursuit of the perfect drive out the good. Kill this idea while you still have the chance and spend your efforts strengthening the system we already have.