Subject: File No. 4-606
From: Richard DeVita

July 30, 2010

The life insurance industry is already regulated stringently on a state by state basis. Applying a "fiduciary standard of care" is the wrong way to think about a variable life insurance policy. These policies are for protection and the variable element of the polcy is by personal choice of the policyholder. This is not an "advisory relationship". I hope you will avoid what I would view as a regulatory overreach that would adversly impact life insurance sales to a public that is already woefully underinsured.
Rich DeVita