Subject: File No. 4-606
From: Archer A Jordan
Affiliation: NAIFA member, ABC (Alternative Benefits Consultant)

August 24, 2010

As a life health insurance broker I frequently come upon clients who have needs for capital accumulation above what whole life insurance affords but who don't want to engage a full fleged financial planner with the associated fees involved. I have been pleased to be able to offer indexed annuities with guarantees of principal and fixed interest rates that also have the feature of higher rates of return if the indexed accounts appreciate at greater rates. To require me to hold a securities license and be a registered representative for a particular security firm would negatively affect my ability to serve my clients and in turn limit these same clients investment options.