Subject: File No. 4-606
From: Kenneth R Davis, CLU, ChFC, CASL
Affiliation: MetLife

July 30, 2010

As a 25 year veteran in the financial services industry, I have seen many changes. 9/11 brought about so many regulartory changes that a rep is now bogged down in paperwork. We have a staff person go over all applications submitted to the OSJ and then the OSJ goes over the paperwork. The paperwork goes to the B/D and it is gone over again. We have securities tests that we have to take at least 2 times per year. We have 3 office visits with compliance officers each year. We have securities training annually also. In order to maintain the insurance license, I have to take CE classes annually. In order to get into the securities business, we have to obtain the state license and the national license. I began with series 63 and now have series 7 license. I also had to take series 66 in order to be considered a financial planner and investment advisor. We are regulated enough. Our paperwork is out of control and we kill many trees daily. I understand we need to protect the consumer although, if you are in the financial services business, you should be doing everything you can to help the consumer and provide them with advice that meets their risk tolerance and situtation. Advice should not be about the rep, it should be about the consumer. Adding another standard will not help the consumer as much as it will cost the companies and evidentially the consurmer. Thanks for your time.