Subject: File No. 4-606
From: Gerald Tyson, CFP, ChFC

August 25, 2010

Everyone placing financial products with the general public should be held to the fiduciary standard of care.

The company which I work for AXA / Equitable along with the AALU seems to be totally against this idea as the suitability requirement can be easily twisted and is open to interpretation. Sales of high commission high profit products would clearly fall if a higher standard were to be upheld.

The marketing schemes and selling practices which I have seen in my 15 years in the business, along with the campaigns, sales incentives, and benefit requirements to place certain products make me sick.
When an agent will lose his/her benefits for the next year if they do not place certain high cost profitable insurance products with prospective clients it is amazing just what becomes suitable.

We have to hold the clients interest first in all cases of placement of financial products to the general public. This should also include so called "indexed annuities" which clearly are being marketed improperly to an ill prepared public.