Subject: File No. 4-606
From: Eric S Howell, ChFC
Affiliation: Principal Financial Group

August 3, 2010

I strongly urge you NOT to pass the new fiduciary standards. The current broker-dealer suitability standards are more than adequate. I have been in busines for 24 years and have seen a significant increase in compliance awareness among advisors, ie suitability and in the frequency of company and state audits to police the adherence to suitability standards. Our company has rigid standards in place that make it almost impossible to sell a product that's unsuitable. That coupled with the numerous disclosure forms ensure the client is fully aware of both costs and benefits of the product they're purchasing.