Subject: File No. 4-606
From: Richard B. McKernan
Affiliation: NAIFA

August 23, 2010

Several years ago I voluntarily surrendered my securities license. I was a registered rep for just over 20 years and had no complaints or problems. I simply found I was spending more time on regulatory compliance issues than I was serving my clients.

The proposed new standards will add more levels of bureaucracy and not truly protect the client any better than the current regulations.