Subject: File No. 4-606
From: Thomas F Levasseur, CLU, MS Ed.
Affiliation: MDRT, NAIFA, SFSP, Chamber of Commerce - Dover, NH

August 6, 2010

I have been a working professional in the investment and insurance business for 25 years. As a member of MDRT and SFSP, and a Chartered Life Underwriter, I have take the professional pledge to in effect, "Do no harm." very seriously. I have never had a complaint filed against me in those years and have held myself to a very high standard of providing clients with the most "suitable" assortment of products and services to meet their individual needs and circumstances. During annual reviews, we discuss changes to both needs and circumstances and adjust their holdings as necessary. The "suitability" standard protects my clients because "I" adhere to it scrupulously. To change this level of care to a fiduciary standard makes no sense at all and is either driven by the "so-called" fee based professional community, who while berating commission base sales professionals, often charge exorbitant fees for little service and then sell high commission products in the plan. Or, it is driven by the ill-founded notion that it better protects the consumer by forcing the sale of the "best" product. Well circumstances often determine the best product and not performance. If a closer eye had been kept on Mr. Madoff, whose performance was so stellar, then maybe we wouldn't be having this debate at all.

Aristotle suggested thousands of years ago that sales... one person using logic, emotion and ethics to convince another to do what is in their mutual self-interest, is both the glue that binds a society together and the grease that keeps it going. The suitability standard fits into this philosophy very nicely and should remain the standard for our industry and profession.

Respectfully submitted by a man who had built a living and a life by caring for the needs of his clients one "suitable" step at a time.

Thomas F. Levasseur, CLU, MS Ed.