Subject: File No. 4-606
From: Julie Hetland
Affiliation: NAIFA

August 5, 2010

I diagree with this act which would change our current'suitability' standard to a fidiciary standard for many reasons. However, I merely will comment on what is in the best interest for a client. I work with many clients who cannot afford to pay an upfront fee. They purchase products that they I feel will benefit them short or long term. To impose this new standard will change my practice to needing to simply charge a fee let them purchase on their own, simply to avoid my chances of future or past lawsuits that would ensue. For the SEC to define 'best interest' of the client is impossible, because every client advisor have a different standard: best quality of product, cheapest product, most tax efficient product, what company/investment has been around for the longest, who is in charge of the fund/company the client is choosing. We are bombarded by compliance being in best practice guidlines everyday. Myself my staff spend about half our time on any particular case to be sure we have done 'best practice' for the client.

Please stay with the 'suitability standard' to avoid making planning unaffordable for the average American.

Thank you
Julie Hetland