Subject: File No. 4-606
From: Fred W Lancaster

August 24, 2010

Re: Fiducuary Standard

As a Registered Representative with NYLIFE Securities, I do not have access to the entire universe of investment and/or insurance products. I am limited to those products that my broker dealer has vetted. The current "Suitability Standard" to which I must adhere requires me to gather extensive information about my client's current financial situation and their goals and objectives. Once this information is gathered, I then make a recommendation(s) which I feel is suitable and in the best interest of my client.

If you impose a full fiduciary standard on my practice (as currently proposed), my ability to serve my clients will be impaired, not enhanced, Clients already expect me to work in their best interest. A full fiduciary standard will only open me to additional legal liability, without enhancing my client's understanding of their goals and objectives. Indeed, studies on this issue have consistently shown that client's do not benefit from a fiduciary standard in terms of portfolio performance versus the current suitability standard.

Please consider a "carve-out" for Registered Representatives who are captive by a single broker/dealer.

Fred W. Lancaster, CLU, ChFC