Subject: File No. 4-606
From: Mark A Miller, LUTCF
Affiliation: Principal

July 30, 2010

I would have you consider the true impact to the lower end consumer of insurance product if the industry moves to a "fee only or fee based" compensation structure. I am not a securities agent nor is my agency. Most of the people we work with either couldn't or wouldn't put money down up front to find out what they need to protect or inhance their financial well being. Those that want that style of service already use it. If you were to look at the average consumer of "fee based" advise, you'll see that most are on the higher end of the income strata. You'll also notice that they work with "captive" companies as opposed to "independent" advisors. That means that they can only sell products or services their companies produce. That would mean that they are unable to "shop" for the best solution to an individual's needs. I am not a "securities licenced" agent, but I would presume that the logic of the regulation being considered would fall into the same application down the road. I hope this is helpful, and I appreciate your consideration. Please feel free to contact me if you have any thoughts you would like to discuss (715.456.8293). Thank you. Mark