Subject: File No. 4-606
From: Richard D Dean
Affiliation: MDRT, Ed Slott Elite IRA Advisor, Group - 1

August 6, 2010

I am adamantly against any additional governance regarding the suitability standard governing broker-dealers because the governance of registered representatives is already a redundant and overly robust and heavily enforced standard. Compare and contrast it to how you see the fiduciary standard governing investment advisers is applied and enforced.

Furthermore, my annual continuing education requirements, EO coverage requirements, mandatory product seminars or education seminars etc. take significant time out of my productive time annually as it is. If anything the regulatory body should seek to streamline the compliance and licensing process, not to continue to bog it down. It is over regulation and redundancies that forces financial planners to have to dilute their time and efforts with their clients. Instead they have to keep seeking new clients (Build a bigger book) in order to survive.

I have been in the financial/insurance industry for 30 years. In my opinion, the continued expansion of regulation is actually becoming a hindrance to the end product to the consumer. Anytime you create an over regulated and to cumbersome process the more apt you are to have failures to adequately regulate. Big is not always better or the answer.

R. Dean