From: david.pusateri@nm.com [mailto:david.pusateri@nm.com] 

Sent: Monday, July 06, 2015 11:01 AM

To: EBSA, E-ORI - EBSA

Subject: RIN 1210-AB32

Dear ERISA Rule Making Team,

I am writing to share how I work with many clients as part of my practice at Northwestern Mutual. I am 

a financial advisor (FINRA Series 6,63,65). I have my CLU® and have completed the courses to sit for my 

CFP®, though I have not taken the exam yet. I work with everyday folks and help them craft a plan for 

their financial security. I meet with a few hundred people a year and have met with thousands over my 

8 years career. I take working with them very seriously. I put in place a full financial plan including 

saving for the short, mid, and long term. We look at their goals and dreams and how they can achieve 

them. I look at ‘offense’ (saving for college, retirement, dream vacations, starting a business, home 

improvements) and ‘defense’ (what happens if someone gets sick or hurt or passes away unexpectedly). 

Invariably I look at their retirement. What they have done, what they want, what their experience has 

been, who helps them, what their options are at work. It takes hours to do all of the planning and we do 

it all and present it to the client for no cost. My model is that I will do such a good job and have some 

ideas that they find compelling and will implement. This could mean purchasing life, disability, or long 

term care insurance or taking our recommendations for starting a 529 college savings plan, traditional or 

Roth IRA, opening a non-qualified mutual fund account, or consolidating their 401(k) plans from 3 

previous employers to an IRA. My only form of compensation is commissions from insurance or 

transaction or advisory fees from investment accounts. They thing is I treat everyone with the same 

care, whether they pay transaction fees or advisory fees. I would say that most times, their biggest asset 

is there 401(k)/403(b) plan at work. However, they are not getting much advice concerning investing it 

and it is often times self-directed or just sitting in the target date fund. The only advice they get is from a 

computer or perhaps the plan’s investment advisor with a once a year meeting that only takes into 

account the retirement plan and no other aspects of the client’s financial picture. People need us Our 

process is so much more comprehensive and relevant to them. Currently, I cannot give them advice 

about their ERISA covered plan and I am only able to offer general investment advice that they can 

translate themselves into their plan. So, I want to voice my opinion that changing the rules so that I 

cannot help with any retirement advice including their IRAs seems counter to the goal of getting people 

better help. My colleagues and I work very hard to help people come up with an awesome plan and we 

should be compensated for our efforts.. They are making far too many mistakes and saving far too little. 

We make a big difference and should not be unduly punished or forced out of the business because we 

are perceived as ripping people off. We have no interest in doing a bad job. Our best marketing is 

referrals from existing happy clients.

Kind Regards,

Dave

David W. Pusateri, CLU®

Financial Advisor

Northwestern Mutual - Indiana

9753 Crosspoint Blvd.

Indianapolis, IN 46256
(317) 284-5339 Office

(317) 985-4329 Cell

(317) 252-0763 Fax

david.pusateri@nm.com

http://www.nm.com/davidpusateri

IN LIC#604199

CA LIC#0G82611

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Northwestern Mutual Financial Network is the marketing name for the sales and distribution arm of The 

Northwestern Mutual Life Insurance Company, Milwaukee, WI (NM), and its subsidiaries. David W Pusateri is 

an Insurance Agent of NM (life insurance, annuities and disability income insurance) and Northwestern Long 

Term Care Insurance Company, Milwaukee, WI (long-term care insurance), a subsidiary of NM, and a 

Registered Representative and Investment Adviser Representative of Northwestern Mutual Investment 

Services, LLC (securities), 111 Monument Cir # 3800 Chase Tower, Indianapolis, IN 46204-5175, 317-238-

6500, a subsidiary of NM, broker-dealer, registered investment adviser, and member FINRA (www.finra.org) 

and SIPC. NM and Northwestern Mutual - Indiana are not broker-dealers. There may be instances when this 

agent represents companies in addition to NM or its subsidiaries.

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