Subject: File No. 4-606
From: Gregory Ronneburger
Affiliation: AXA Advisors Divisional Vice President

August 11, 2010

I feel very strongly that any additional fiduaciary layers on top of an already heavily regulated industry is unnecessay and potentially damaging to the insurance industry. As it stands now, AXA Advisors employs full-time compliance officers in each of its branch offices. These officers regulate every sale and transaction made for each client of AXA. Additionally, we have a corporate compliance department constantly regulating everything that we do. This is in addition to the regulatory oversight of FINRA and the state insurance departments, whose strict laws already make it difficult to fully serve our clients because so much time and effort is spent responding to compliance requests.

Adding another layer of responsibilities will also force costs to increase, since more staff will be needed, more systems will be put into place, and more software and hardware will have to be purchased. The industry is very competitive and the public is very price-aware, so margins are not very high on many products. Adding additional costs will increase fees on some products, which will make customers respond by not making the purchases. I don't feel that we should be increasing the cost for consumers to purchase insurance and investment products. Rather, we should be making the public more aware of the need to protect their families and save for themselves since corporations and governmental programs can no longer sustain the ability to take care of everyone throughout their retirements.

In closing, most financial advisors and insurance agents act in the best interest of our clients. Sure there are some that do not, but this is true in any profession. Putting additional regulations and costs into the industry will ultimately force more good, honest agents out of the business because of frustrations and increased costs. Having less reputable financial advisors and insurance agents servicing the American public is detrimental for our society as a whole. Please do not add regulation to an industry that is already heavily regulated without taking time to consider whether it is really appropriate and necessary.