Subject: File No. 4-606
From: LEO O WHITLOW, JR
Affiliation: President - NAIFA Richmond, VA

August 24, 2010

- I am a financial advisor and have been for 34 years. I am regulated enough already I currently hold a life/health license, Series 6,7, 63, and 65 licensces as well as long term care license. The way we are now regulated is that our fiduciary standard looks forward and tries to prevent harm to consumers through ongoing and frequent FINRA and broker-dealer audits and compliance processes. That is much better than the proposed "look back" method that only enforces breaches retroactively. I just finished up my yearly compliance testing that took a whole day to finish. I have the following to complete: 1. Firm Element Training
2.Anti-money laudering
3.2010 variable annuity training
4.Annual compliance questionaire
5.Face to face compliance meeting with my internal compliance officer
what more do you need? What you are doing will only force us to go to a fee only model which will not be used by as many cleints. A great deal less people will be served by this model than what we have now. My fees that I will pay will go up because my liability insuracne will cost me more which I will then have to pass on to my clients. It might drive me out of the business Stop now and don't vote for this new measure. Leave well enough alone. We want less government - not more