Subject: File No.
From: Robert L Rifkin
Affiliation: NAIFA, MassMutual

October 28, 2010

Allowing B/D's to compete for business based on commissions is very dangerous to the consumer. Price alone should not be the determinig factor for a financial product acquisition.

An advisor who has the ability to spend time learning the products and properly servicing his or her clients must invest money in their practice. Continuing education and client management systems are expensive if done correctly. To be able to spend the appropriate amount time with clients to make the proper suitable recommendations also costs the rep time and money. Should the consumer be able to buy funds at lower cost but have no regard to the level of service or product specific knowledge or competing product knowledge the rep has?

If what you are looking for is low price, low service and an unknown level of product information than go ahead and allow B/D's to charge what they want and let the buyer beware. I do not think this is what the SEC wants and the consumer wants. Isn't it better for the charges to be clearly visible to all potential buyers of financial products and then they can make a decision based on who they are more comfortable working with versus price alone?

We had too many people financially hurt because of a lack of information. I truly believe the same will happen if commission competition is allowed. It is quite logical that education, due diligence and service will suffer if the lowest commission is all that matters.