Subject: File No. 4-606
From: Robert E. Thompson, CLU, ChFC
Affiliation: National Association of Insurance Financial Advisors

July 30, 2010

To whom it may concern:

As a an Investor Advisor representative and broker for my Broker/Dealer, I feel it important to tell you that we are already regulated enough. I respect your desire to protect our accountholders from irreputable brokers and advisors. However, more regulation will not protect the individuals who are purchasing investment products from the few bad apples in our industry or any other industry. They will show up no matter how much you try to regulate them out of the business. It seems to me that the only ones protected by more regulation are the regulators (such as the SEC FINRA) that oversee our business, since most accountholders already feel bogged down by all the hoops we make them jump through to purchase our products.

Dishonest people thrive in a society that teaches it is okay to misrepresent or cheat, if they feel it is for their greater good. Perhaps what we really need is a greater emphasis on high moral and ethical values in our culture and educational institutions, if we really want to protect the consumer. Dishonest people always seem to find a way around any laws or regulations we try to impose on society and them.

You have been doing a good job with the regulations you already have. Just continue to enforce them and remember that we are going to continue to need the enforcement of the regulations already in place, but we cannot eliminate those who want to get ahead by unethical, immoral, and illegal means. We must, however, continue to prosecute those who have proven to be purposeful violators of the regulations already in place.

Thanks for your attention on this issue.

Respectfully submitted, Robert E. Thompson, CLU, ChFC