Subject: File No. 4-606
From: Shane M Swanson, CLU, ChFC, CFP, CLF
Affiliation: Zone Vice President, New York Life Insurance company

July 31, 2010

I have been a member of the industry for 18 years on the life insurance side of financial services. I am also a Registered Investment Advisor and Registered Securities Principal. Submitting Registered Reps (many of whom in our industry just have the Series 6/63) to the same fiduciary standard as an RIA is unwise and unnecessary.

In our model, we have a proven oversight process with our Registered Representatives. Most of our Reps limit their focus to mutual funds and variable annuities. Don't paint life insurance agents with the same brush used for the brokerage industry. Our primary goal is to help insure the continuing financial security of Americans through our Protection, Accumulation and Distribution products. We were recently named Fortune Magazine's "Most Admired Insurance Company in the World" in part because of our fair and safe business practices.

Putting the fiduciary responsibility on life insurance agents would be onerous and unnecessary. Thanks for considering my opinion.


Shane M. Swanson, CLU, ChFC, CLF, CFP
Zone Vice President
New York Life Insurance Company