Subject: File No. 4-606
From: Stephen C Owings
Affiliation: CLU, ChFC, CFP

August 2, 2010

This fiduciary idea is misguided in my opinion. I, like most of my colleagues, spend a great deal of time money doing my best to comply to the myriad rules that already exist. Now that we've had the blow-up, it seems that the usual thing is happening: punish the innocent.
The Madoffs of the world never paid attention to the already existing rules but got away with it for decades. People like him won't pay attention to the new rules either.
What would be most effective would be to put additional resources and effort toward enforcement of existing rules...changing the rules to be more stringent (punish those of us who are have been compliant) only adds overhead takes time away from being with the clients we seek to assist in achieving their financxial goals.