Subject: File No. 4-606
From: Donald J Scaro, CLU

August 6, 2010

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

The liabilities of a fiduciary duty would mean increased costs.
Will moving to a fee-only model result in better, unbiased advice?
Will we be forced to a fee only model to protect yourself from liability?
Can our clients afford to pay up front fees or will they be willing to?
Will the liabilities drive up our errors and omissions coverage?
Will we be able to stay in the business if liabilities become too great?