Subject: File No. 4-606
From: Dennis R Farrar

August 24, 2010

I am a registered representative and an agent for New York Life. I do not believe that changing the fiduciary standard of registered representatives and the brokers they represent will be a positive impact for our customers. I believe that we should focus more on "looking forward" to make sure that brokers and registered representatives are compliant rather than ignoring the present and the future and allowing for litigation to control the process. Our court systems are already overburdened and this legislation will further force our courts to be clogged up with unnecessary litigation. The fiduciary standard will change our profession much like the litigation of malpractice has changed the medical profession. Errors and Ommissions insurance will skyrocket forcing the customer to absorb the bulk of the cost. Much again the same way health care has spiraled out of control.
At New York Life we have a full time compliance officer on our staff. He is responsible for completing compliance education and audits for all agents not just registered representatives. By taking the proactive stance we as agents are always required to "do the right thing" for our clients and always look and ask the client for their needs first. Let's not add any more regulation to our industry.