Subject: File No. 4-606
From: Philip M. Maness, ChFC
Affiliation: Financial Consultant, AXA Advisors

July 30, 2010

Because the fiduciary standard looks retroactively, it does little to protect consumers from financial service reps who would do them harm. And it would add other layers of regulation on top of the existing cumbersome regulatory structures in place. We already have too much burdensome government regulation to start with and the proposed changes would only serve to exacerbate the growing problem of focusing on our clients in an onerous legal and compliance atmosphere.