Subject: File No. 4-606
From: michael j kiley
Affiliation: CEO Chamberlain Group

August 28, 2010

Including life insurance agents and registered reps under the fiduciary standard will damage the life industry and hurt the consumer. Life insurance is a complex product with limited transparency for competitive reasons.It cannot be unbundled and evaluated like an investment portfolio. The ultimate costwill only be known over time based on the performance of the carrier and the product. It cant be evaluated like a commodity based on price.
After 35 years in both the investment advisory RIA role and life brokerage business I can attest to the fact that they are different business models and cannot be regulated under the same standard.