Subject: File No. 4-606
From: Rose L Goheen
Affiliation: President NAIFA Tidewater

July 30, 2010

It is my belief that the proposed fiduciary standards legislation is not warranted. I am a 27 year multiline agent with State Farm and hold a 6 and 63 license. I am already subjected to an annual audit of my securities related transaction, submit to 2 compliance meetings and a NASD Firm Element meeting. All materials given to our clients are reviewed and all fees and sales charges are openly disclosed. Before any securities product is offered, we go through several discussion conversations and ultimately a risk profile to determine the suitability of the security for this client.

Since we are already under several layers of compliance from NASD and our sponsoring company, this legislation is redundant and cost ineffective.

Rose l. Goheen, CLU