Subject: File No. 4-606
From: Debbie A Homan
Affiliation: National Assoc. of Insurance Financial Assoc.

August 2, 2010

I just want to make my point clear the I believe the suitability standard governing broker-dealers registered reps is a robust heavily enforced standard. Compare contrast it to how you see the fiduciary standard governing investment advisers is applied enforced.

Compliance costs both in terms of finances and time are high. Those costs are eventually felt by clients. Adding anothe rlayer of regulation means another layer of compliance even more cost to clients.

Everyday I am examined by compliance by the paperwork that has to be completed for each client, reviews in our office, testing every three years at a computer site, and the list goes on.

I would not want to move to a fee only model of doing business. That again, would effect my clients costs.

I would be forced to go into another line of work if it comes down to being a fee only based business.

Please consider my comments when making your decision.
Debbie Homan