Subject: File No. 4-606
From: Robert E Recchia, CLU ChFC
Affiliation: President, California Corporate Benefits Insurance Services

August 1, 2010

I believe that investors and the investment industry will be best served by requiring participation in and completion within a reasonable period of a professional course of study such as already exists (CLU, ChFC, CFP, CFA, AIF etc.) The organizations sponsoring the certifictions must be given a stronger mandate to self-police and teeth in their power to discipline.

Please, please, do not add more paperwork. Already my firm can no longer afford to serve the needs of investors with balances under $250,000. This leaves the newest investors, those with the worst experiences and the least investment saavy to seek advice from advisors with lower skills or even none at all.

I represent a great many advisors in my industry that would love to help the investor on main street. Regulation, however, makes that all but impossible except as charity. The ever increasing paperwork burden imposed by broker/dealers due to fear of regulators requires too many hours to complete for small accounts. I also fail to see how all the hours of new paperwork already introduced to the industry has helped anyone.

The real issue is training and ethics.