Subject: File No. 4-606
From: Renee A Montenyohl

August 9, 2010

"Comments attached" The new standard they would hold us to would be impossible to judge. Best investment by what? The performance, cost, ratings, return pre-tax, return after-tax, it would be almost impossible to have a best investment in all catagories. It just leaves the interpretation open to to many variables. How would a captive agent be able to provide any services? It would require our knowledge of all products all the time also virtually impossible.