Subject: File No.
From: David Belk, CFP
Affiliation: Society of Financial Professionals, NAIFA GrassRoots Past President

October 30, 2010

The consideration of allowing BD's to set comp should be considered another form of rebating and does not guarantee service levels that would be sustainable even for larger firms.

While national firms may see this as a potential positive long term, it would only be from the perspective that it may place many small, regional, and/or limited BD's, in a position that they could not operate under lower pricing and the larger firms may benefit by picking up additional reps and they survive from a volume perspective.

The focus to "regulate" pay does not address the issues of our industry or country.