Subject: File No. 4-606
From: Paul B. Crouch

August 6, 2010

I have been in the Insurance industry for over thirty (30) years, and a Registered Representative for seventeen (17) years. Over the years, I constantly receive more layers of regulation. Enough is enough. Adding another layer of regulation means another layer of compliance, and even more costs to consumers.
I must fulfill core requirements through my Broker/Dealer and study for, and pass on-line course requirements. I probably take 8 - 10 course requirements, per year. This year I have an additional FINRA requirement. In addition to these requirements, the paperwork that is required for all transactions is becoming burdensome.
Also, moving to a fee-only posture will NOT result in better, unbiased advice. Many of my customers can not afford to pay up-front fees, nor are they willing to do such. There are areas of compliance that do not add any consumer protection that I must follow.
There is a PERCEPTION that the legal fiduciary duty governing investment advisors provides greater investor protection than the suitability standard governing Broker/Dealers. This PERCEPTION is FALSE.
Paul B. Crouch