Subject: File No. 4-606
From: Victor W Kirsch
Affiliation: AXA Advisor

July 30, 2010

Please stay the course on the suitability standard and do not adopt the fiduciary standard.

We are a heavily regulated industry now. We spend a great deal of time complying with present regulations.

At some point many of us would be unable to deal with all the requirements from a time and expense standpoint and be driven from the business.

Every year I pay death claims on life insurance I have sold. And make no mistake, life insurance is sold and not sought out by the consumer to buy.

Less advisors means less insurance sold. Who will then take care of the families who needed those precious life insurance dollars. And who will employ the laid off employees of a failed company because the owner died, the bank called the note and there is no choice except to close the door?

And what is "best"?... cheapest, best ratings, service?? If you don't sell the cheapest, you get sued, or you did sell the cheapest but the company has poor service, you get sued. Or you sold the best rated but product cost are higher to support the ratings

Every single family could sue you because you sold term (temporaty insurance which almost always lapses before the death of the insured) Even if that was the only insurance the client could afford.

The SEC and families/business could always look back and argue what you did was wrong, even if it was the right thing to do at the time. AND that is not right

Consumers will pay higher rates for products becasues increased expenses will be passed on the consumer.

Please let the suitability standard be standard we can and do embrace and thank you for your consideration.