Subject: File No. 4-606
From: Joseph E Whipple, Jr.
Affiliation: NAIFA

August 26, 2010

With this new regulation, it seems that the negatives are going to outweigh the positives. In this industry, with all the information that is out there and the increased regulations that have come about over the past few years, I already must work in a fiduciary capacity, or else my practice will suffer. In fact it wouldn't just suffer, it would dissolve. Reputation is everything and people catch on fast. Let's not do damage to an industry that through these last few years, has been able to maintain its integrity, unlike some investment banks and other insitutional banks. In fact, as an agent with New York Life, I feel our reputation has grown immensely since the recent crash. I say no to the imposition of a fiduciary standard.

Ed Whipple