Subject: File No. 4-606
From: John K Simons
Affiliation: Registered Representative, NYLIFE Securities

July 30, 2010

I am writing to express my opposition to the SEC imposing mis-guided fiduciary responsibilities on Registered Representatives. For 34 years I have served as a registered representaive and have developed a successful business and personal relationship with hundreds of clients. I work in a small town in Southeast New Mexico and own my office on Main Street with my son who is also a registered representative. We both have Chartered Life Underwriter (CLU)designations. I also have the Chartered Financial Consultant (ChFC) designation and my son is a Certified Financial Planner (CFP). We take pride in always doing what is in the best interest of our clients. Our broker dealer requires us to follow all SEC regulations and inspects us regularly to insure we are in compliance. In a small office like ours we already spend a great deal of time making sure we are in compliance with all the rules and regulations that already exist. If you impose more fiduciary liability on us we fear that our professional liability insurance premiums will increase, we will be forced to hire more staff, we could be forced into working only on a upfront fee basis with our long time clients, and forced into providing certain products based only on the "cheapest cost" not "best value" basis. It could potentially force us out of the business. Please do not impose these mis-guided fiduciary responsibilies on registered representaives.