Subject: File No. 4-606
From: DAVID P OPPEL

August 30, 2010

I AM THE OWNER OF A TAX ACCOUNTING BUSINESS AND A REG. REP. WITH NEW YORK LIFE INSURANCE. I HAVE BEEN WITH NEW YORK LIFE FOR THE PAST 26 1/2 YEARS. I HAVE 3300 CLIENTS IN VARIOUS STATES. I FOLLOW ALL REGULATIONS IN ALL STATES. I HAVE NEVER HAD A PROBLEM WITH THE CURRENT SUITABILITY STANDARD GOVERNING BROKER-DEALERS AND REG. REP. I AM CONCERNED THAT WITH ADDT'L LAYERS OF REGULATIONS THAT I WILL HAVE ADDT'L TIME SPENT ON THE REGULATIONS AND ADDT'L COST TO COMPLY WITH THE DIFFERENT STATES FOR SUCH REGULATIONS. I CURRENTLY SPEND UPWARDS OF $6500 PER YEARS JUST IN REG. FEES. I HAVE A FULL TIME EMPLOYEE WHO SPENTS 30 HRS PER WEEK JUST ON MEETING COMPLIANCE ISSUES. THIS EMPLOYEE IS PAID $45,760 PER YEAR FOR HER SERVICES. I CURRENTLY DO NOT PASS THIS COST TO THE CLIENTS. I MEET WITH MANY CLIENTS THAT I MAY NOT BE ABLE TO HELP WITH PRODUCTS. I GET PAID ONLY IF THE PRODUCTS WE HAVE ARE A GOOD MIX AND PROPER FOR THE CLIENT. IF THE COMPLIANCE ISSUES ARE CHANGED, I WILL BE FORCED TO A FEE-ONLY PLATFORM DUE TO ADDT'L LIABILITIES. I DON'T FEEL THAT A LOT OF CLIENTS WOULD WANT OR CAN AFFORD UP FRONT FEES FOR THE SAME SERVICES I CURRENTLY PROVIDE. I HAVE ALWAYS FELT THAT IF I DO THE PROPER JOB FOR MY CLIENTS-THEY WILL RETURN AND CONTINUE TO USE OUR SERVICES. IF I USE A FEE-ONLY PLATFORM, I QUESTION IF MY CLIENTS WOULD BE AS COMFORTABLE AS THEY ARE NOW AND I DON'T THINK THIS WILL PROTECT MY CLIENTS. A CLIENT MUST BE INVOLVED WITH THE PLACEMENTS OF PRODUCTS AND SERVICES. BOTH THE REG. REP. AND THE CLIENT HAS RESPONSIBLITIES IN THE PRODUCT OR SERVICES PLACED.

I FEEL THAT THE CLIENT SHOULD BE BETTER EDUCATED ON FINANCIAL PRODUCTS PRIOR TO PLACEMENTS-I DON'T SEE FEE-ONLY PLATFORMS PROVIDED THIS SERVICE. WE REQUIRE THAT A CLIENT REVIEW ALL RECOMMENDATIONS PRIOR TO PLACEMENTS. IN THE 26 1/2 YEARS WITH NEW YORK LIFE-I HAVE A 97% RETENTION OF OUR PRODUCTS PLACED. THIS IS DUE TO MY OFFICE PROVIDED CONTINUED SERVICE AFTER THE PLACEMENTS AND EDUCATION PROVIDED PRIOR TO AND AFTER THE PLACEMENTS OF PRODUCTS AND SERVICES.

THE CLIENT IS OUR PRIMARY CONCERNS.

DAVID P. OPPEL