Subject: File No.
From: Dennis J. Shepherd
Affiliation: President

July 21, 2017

Our retirement advice given in our commission only based operations is by performing a complimentary retirement plan projecting their lifetime income vs expenses and what ifs. Thus with our systems we have proof of due diligence as independent agents to provide products that are suitable to our clients. Without the DOL fiduciary standard we show our clients how our products provide i.e. less risk or more protection ect. Thus we serve our clients best interests. In addition we must complete a suitability forms to show we have done our due diligence. The fiduciary rule will force all insurance agents to become licensed security advisors. Why? Why must they give advice on both investments since the client can be served by both the insurance agent and the securities advisor. Thus all clients can be served by a commission and by fee based depending on the size of the investment or premium. The rule would pose more restrictions on giving advice by both the insurance agent and the advisor when both can give advice for their clients. Since we provide these retirement projections we feel we are under pressure to perform both when it is not necessary for the clients we serve. Thus my EO costs are going up to continue to provide the good advice we are have been providing.