Subject: File No. 4-606
From: Patrick V. Wippel, CPCU, CLU
Affiliation: member of FSP and CPCU Societies

August 20, 2010

The existing level of regulation of Broker Dealers and Investment adviosors (when enforced evenly and effectively) should be far preferable to an added level of regulations scheduled to be enforced by additional levels of supervision by individuals of varied qualifications. I question whether Suitability would work as effectively as fiduciary or principles based standards.