Subject: File No. 4-606

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.

I am licensed I hold Series 6,63 and property casualty and life/heath insurance licenses and not only comply with continuing ed requirements but exceed it so my clients have a knowledgable professional they can work with. Additionally I teach some continuing education.

I am examined yearly.

Moving to a fee-only model will not result in better, unbiased advice. I believe my industry is already acting in the "best interest" of their clients, the Act does not define what the rules are for compliance with a legal "best interest" standard - thus subjecting registered representatives to the potential of never ending lawsuits...which are costly and time-consuming.
Are clients have be decimated financially these last years...many cannot afford to pay their normal bills and will be both unable and unwilling to pay upfront.
It appears unfair to place the burden on an industry that is so highly regulated by placing unfair liabilities that may become too great to absorb.

I would like to know what I can do to convince the SEC to not exercise their authority to impose a misguided fiduciary standard.