Subject: File No. 4-606
From: T. Jay DiBacco
Affiliation: National Association of Insurance and Financial Advisors General Agents and Managers Association International

August 13, 2010

Hello, I have been in the Life Insurance industry 30 years, and have served my clients in a professional manner, regulated and reviewed by my broker dealer on an ongoing basis. This system works

Over the years I have noticed that the most publicised and damaging infractions from the financial services profession have come from the folks under the 'fiduciary standards' that you propose to extend to folks like myself.

I confess that frankly I do not understand your reasoning.
Please consider:

#9650 Suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards.
#9650 Requiring compliance with 'fiduciary standards' will drive many advisers out of the market and eliminate a valuable advisory resource to consumers, especially in middle- and lower-income markets.
#9650 Additional risk of lawsuits involving registered representatives will increase costs to consumers.
#9650 Driving every registered representative to fee-only compensation will not necessarily result in better, unbiased advice for the consumer.

Don't fix the part that is working the best - do something to improve the efficiency of enforcing the rules for those already under the 'fiduciary standards'.

Thank You,

T. Jay DiBacco
Registered Representative