Subject: File No. 4-606
From: Dan R Elser, CLU, ChFC

August 24, 2010

I want to encourage you to get good input from all groups concerned before taking action on applying stricter standards to Broker/Dealers and Registered Reps. I have been in the business 35 years and seen the results of increased regulation increase cost, add addition layers of personal equipment which takes away time from selling and servicing cleints in a alreday complicated world. I believe we should be very diligent in careful hiring and training of those serving the public and to quickly deal with dishonest people (there are several I know who got their hands slapped and returned to the industry later). The market we are in today is so large it would be impossible to research the vast change in products occurring daily and what about those who are career with one company and can look to other solutions. I believe that careful hiring/supervion, education and training for those in the business has suffered do to increase in compliance and regulation. There are two many Americans who are not preparing for the future because there has been a decline of good quality reps. The old good ones are retiring and we are not developing enough new good ones. The drop out rate is already bad (only 1 in 10 make it). It takes 5 years to learn thr business and the mentorship of high quality and ethical existing producers. Thanks for reading my comments.