Subject: File No. 4-606
From: Jason L Moehring, CFP

August 6, 2010

Fiduciary Standard
I feel this would add an additional level of regulation that would cost my office and company to much additional time and resources to comply with.
I am currently a CFP ( certified Financial Planner) and with the amount of regulation and oversight that is placed on me for compliance for my series 6,7,63,66 and insurance license, I must spend 5 hours a week to comply with regulation now. I also have one full time employee in my office to keep us in compliance with current laws. I am also audited every 6 months from the company that I work for to prove to them we are on top of current law.
If this change went in to effect I would have to drastically change my business practice and move to a fee only service. If I did that I would also have to eliminate around 800 of the 950 households that I serve because they do not have the means to pay the fees charged, do not have the level of service needs, or refuse the fee serves that we all ready offer.
To add this level of fiduciary duty will not result in better advise to clients. To add this level of duty will drive more people out of financial services. If the cost of adding more staff and time out of meeting with clients is to great from to much regulation I will leave the business.

If this fiduciary standard goes into effect and I loose 85% of my current client base because they would not choose a fee based service to invest $6,000 a year in an IRA I will leave the profession.