Subject: File No. 4-606
From: Raimundo Molina

August 2, 2010

Placing a fiducuary standard on insurance agents selling life insurance will place an additional level of regulation on agents that are already heavy regulated.

If done so this will increase costs that will have to be passed down to the insured through increased premiums. This will not happen immediately but it will happen.

Also it is important to define exactly what the standards will be. "Best Interest" to the client can be measured by many different metrics: lowest premium, best coverage, best underwriting, best rating for carrier, or any other metric that anyone can think of. It must be well defined if not there will be increased litigation when a customer does not think their interests have been served.

We must serve our customers and take care of them, but we need time to serve them and use less time in being compliant with so many laws and regulations.

For all these reasons I'm not in favor of placing the fiducuary standard, however, if it must be placed to define very well the responsabilities that must be assumed.