Subject: File No. 4-606
From: Gary T Havir
Affiliation: National Association of Insurance and Financial Advisors(NAIFA)

August 4, 2010

We are regulated enough already.

I disagree that the fiduciary standard has protected consumers better. Basically, the fiduciary standard looks back and enforces breaches retroactively through SEC enforcement or private lawsuits. The suitability standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes.

The amount of time we spend on compliance already it way too much. While I understand the need, all of the compliance requirements are affecting our ability to serve clients who have a need for the products.

It may raise the my costs of doing business so much that I might choose to retire or get out after 33 years of serving my clients professionally and ethically.