Subject: File No. 4-606
From: Dirk Milestone
Affiliation: Insurance Agent, NAIFA Member

July 30, 2010

I would like to start off my saying that the suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard.

Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.

I, as an insurance professional, have gained the trust and loyalty of my clients. I am already subject to a fiduciary responsiblity that I take very seriously. I am concerned that the Dodd-Frank Act will not necessarily be in the best interest for my current and future clients.

Those who the Dodd-Frank Act are trying to protect will ultimately be the ones who will be hurting by a fee based consulting service rather than a free consulting service that many professionals like myself offer today. With more regulation, there will be more overhead in my office that someone has to pay for. Who? My clients. My book of business is NOT made up of high net worth clients. My book of business is made up of husband and wives with children who are trying diligently to save for their families future. Now, I may be subjected to having to charge a fee.

May professionals already charge a fee for their services and now that fee will be subject to an increase.