Subject: File No. 4-606
From: James E Stearn
Affiliation: NAIFA

July 30, 2010

Please reconsider this regulation as I have multiple layers of regulation now to assure the protection of my clients:
-I have a two dedicated compliance officers with y firm that monitors and advises me on all securities.
-I'm required to attend a compliance meeting each year
-All emails to and from are monitored before being released
-24 hours of continuing education credits are required every two years.
-an anti-money laundering course is required each year and a senior security compatability course is required every two years

Thank you for your consideration.

James Stearn