Subject: File Number S7-15-10

October 28, 2010

Comments on proposed rule making broker dealers the decision makers on service fees.

One must wonder what regulators have learned over the last 30 years from accumulated evidence on deregulation in financial services.

Were bankers and savings and loan owners and directors, schooled in the most expensive business schools, endowed with enough common sense to avoid shooting themselves in the foot?

And what about all the highly compensated, sophisticated, Nobel laureate types from the securities world?

And how about the government entities that were presumed competent to regulate excesses and compliance in the financial system?

What is the malfunction you are seeking to cure? Who said it was a malfunction? What is the empirical evidence for the allegation of malfunction? The government sought more competition by doing away with the Glass Stiegel Act (cost savings/economy of scale/presumed synergies) and it has been a very poor bargain.

Those moving this proposal are, if at all, only dimly aware of the down side, the unintended consequences side, of inviting a "least cost" paradigm in providing financial services to individuals. The underlying presumption of excess cost to the consumer is a speculation. Paying less, the consumer will necessarily get less and the cost to the consumer of finding that out is unknown and potential disastrous.

In the mortgage world, who was there to counsel people being approved on no doc mortgages? People need more, not less, financial counsel. They will not get it by paying less.

Those proposing to enact a "value for less cost" environment in the world of financial guidance are presuming providers are smart enough to know when to stop competing on cost and the individual investor is smart enough to know the boundary of too good to be true.

The financial wreckage in our financial system facilitated by deregulation, aka presumed wisdom, defies the assumptions moving this proposal.

Joseph F. O'Connor, CPA, CLU, ChFC

Financial Representative