Subject: File No. 4-606
From: Derek C Adnams, Jr.
Affiliation: Financial Services Professional, New York Life

August 25, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard.
Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.
o I hold the S7, S63, S26, as well as several industry designations (CMFC, CRPC, CLTC) and must complete CE for each one , as well as my Firm Element requirements.
o There areas of compliance that do not add any consumer protection, such as the redundancy on multiple forms for a single transaction