Subject: File No.
From: Robert H Barnette
Affiliation: Vice President of The Life Division

October 27, 2010

I am a registered rep however I am not actively soliciting at this time, but I have seen agents in the past who gave advice when they were not as knowledgeable as they should have been. I can't imagine opening up the playing field by letting those same agents lower their commisions so they could get more business. I am opposed to the idea of any broker or broker dealer using their commissions to compete for business. I personally feel that too many insurance companies got into the variable product arena without properly training their workforce. I have seen this in day to day insurance operations with small life policies and now I have seen it with insurance companies moving into the variable market. Just because an agent got a license to sell a product doesn't mean he is capable. With the changes that have been made to supposedly educate the consumer, maybe rules should be made that a certain amount of insurance education should be required by the brokers and broker dealers before allowing them to present products, and I am talking about more education than is currently required.