Subject: File No. 4-606
From: Sam Shada

August 24, 2010

The Insurance and Financial Services Industry has so many obstacles for the new agent to overcome that the failure rate is unacceptable. The licensing, compliance, and risk, including expense, is such that Agent success is restricted. Success is Capitalist Driven in our society and as we expand the compliance requirements we tax the new Agent so much that the industry is shrinking.

Adding more fiduciary duty means more costs and much like the impact of malpractice on the medical field we will see that fewer and fewer agents will be able to afford to maintain their agency. As with any additional cost to operations the net cost is passed onto the customer. This makes the product costs go up and thus eliminates a number of clients from participating.

The net result of this summary is that adding Bureaucratic pressure to the industry actually deters New Agent success and forces the costs upon the Customer.