Subject: File No. 4-606
From: Michael T. Wahl
Affiliation: MassMutual Financial Group

July 30, 2010

Threee to five years ago, I sent an email to the SEC with the following wording: "I am convinced that the SEC means well." In execution of its layers upon layers of compliance rules and regulations, the SEC falls in the abysmal trap of unintended consequences. The results of excessive paperwork is, in effect, driving the smaller investors out of the market. It already is very hard to economically provide education and guidance to investors as is. As is, serving the small investor is tantamount to pro bono work. Moreover, there is far more harm done by do-it-yourself investors to themselves than the already oversupervised registered representatives can do to investors. So much time and effort is already wasted by the industry by, in effect, penalizing the overwhelmedly majority of registered representatives that are both honest and hardworking........., in an attempt to restrain the much smaller number of rogue registered representa-
tives. I would make a bet that it takes at least five times as much ultimately investor monies to find one dollar of registered representative error or unintended ommission. I have been in the industry now for four decades and am probably in the top ten percent of the industry. I have had one complaint in those decades of service to my clients and that one complaint was misguided by a competitor to wrest the client away from me. That was over thirty years ago. My files confirmed that the complaint was unjustified. Yet, today I spend more time and effort on paperwork than I do meeting clients....., on roughly a two-to-one basis. I could do twice as much serving the public meaningfully were it not for the onus of redundant paperwork. M. T. Wahl